Notice was issued under section 148 of the Act after a period of four years from the end of the relevant assessment year. The same was challenged by way of a writ petition before the Bombay High Court. High Court observed that though the reasons recorded stated that the assessee had failed to fully and truly disclose “the following material facts”, the Assessing Officer omitted to mention what were the material facts which the assessee had failed to disclose. High Court observed that it was well settled that the reasons recorded by the AO cannot be supplemented by filing an affidavit or making oral submissions and that the reasons recorded must be clear and unambiguous and should not suffer from any vagueness. High Court quashed the notice issued under section 148 of the Act as there was no disclosure in the reasons as to which fact or material was not disclosed by the assessee fully and truly and which the AO thought, was necessary for assessment of the relevant AY. High Court further observed that the assessee had along with the return of income also filed annual accounts certified by the Chartered Accountant/ Auditor wherein a clear reference was made to the fact which was the subject matter of reopening. Accordingly, the assessee had disclosed fully and truly all the material facts that were alleged to have been suppressed. (AY. 2012-13)