Reassessment under the old scheme – Reopening under section 148 – return processed under Section 143(1) – reasons stated that Capital Gain not disclosed by the assessee – Petitioner had filed objections and pointed out that capital gains were disclosed – objections rejected – Petitioner filed a writ stating reopening was invalid as the entire exercise of reopening lacked validoty as the same was on totally irrelevant and incorrect facts as the petitioner had filed return of incone and had disclosed the capital gains – Revenue’s counsel pointed out that reopening was valid in view of Rajesh Jhaveri. Held – reopening was invalid as the same lacked validity since the entire exercise was undertaken on incorrect facts.