Reopening in absence of failure on the part of assessee to disclose fully and truly all material facts is illegal

It is not in dispute that the petitioner had placed all the relevant records, including the construction agreement, before the passing of the original assessment order. Further, it is not the case of the respondent that the petitioner had suppressed certain material facts, due to which the original assessment order, passed by the respondent is liable to be re-assessed.

In such circumstances, in the absence of the failure on the part of the petitioner to disclose fully and truly all material facts necessary for the assessment y

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