Judgment :- Petitioner seeks to quash Exts. P12 & 13 notices issued under S.148 of the Incometax Act, and Ext. P16 letter by which the first respondent rejected his request, for disclosing the grounds for issuing the notices. There is a further prayer to direct the second respondent to dispose of Ext. P4, an application under S.273 (A) of the Act. 2. Petitioner was assessed to income tax for assessment years 1982-83,1983-84 & 1984-85 by Exts. P1 to 3 orders, on the basis of revised returns filed by him. Subsequently, penalty and interest were also levied. On appeal, the levy of penalty was set aside by Exts. P8 to 10 orders. A petition filed by the assessee under S.273(A) of the Act (Ext. P4) is still pending consideration. 3. While so, the first respondent issued notices under S.148 (Exts. P12 & 13) proposing to reopen the assessment for the year 1984-85, and requiring the petitioner to file returns. Petitioner by Ext. P14, and his representative by Ext. P15, told the first respondent that the assessment completed on the basis of revised returns cannot be reopened, as the returns were filed at the instance of the assessing authority and that too on the understanding that the matter would be closed with that. Petitioner stated further that he was not bound to file returns pursuant to the notices, as the first respondent had not disclosed the reasons for reopening the assessment. In reply, first respondent by Ext. P16 informed petitioner that there was no need to disclose reasons and that the only precondition for reopening an assessment, was that the assessing authority should record reasons therefor, in the order sheet. 4. Counsel for petitioner submits that the first respondent cannot reopen an assessment, without disclosing the reasons, which persuaded him to such a course. To support the contention, he relied on the decision in Income-tax Officer, Calcutta v. Lakhmani Mewal Das (AIR 1976 S.C 1753). The Supreme Court held that, "The powers of the Incometax Officer to reopen assessment though wide are not plenary. The words of the statute are "reason to believe" and not "reason to suspect". The reopening of the assessment after the lapse of many years is a serious matter. It is, therefore, essential that before such action is taken the requirements of the law should be satisfied". The words of the statute are "reason to believe" and not "reason to suspect". The reopening of the assessment after the lapse of many years is a serious matter. It is, therefore, essential that before such action is taken the requirements of the law should be satisfied". Counsel relied also on the decision in M/s. Ganga Saran and Sons Pvt. Ltd. v. The Incometax Officer & Others (AIR 1981 S.C.1363). The Court observed: It two distinct conditions must be satisfied before the Incometax Officer can assume jurisdiction to issue notice under S.147(a). First, he must have reason to believe that the income of the assessee has escaped assessment and secondly, be must have reason to believe that such escapement is by reason of the omission or failure on the part of the assessee to disclose fully and truly all material facts necessary for his assessment. If either of these conditions is not fulfilled, the notice issued by the Incometax Officer would be without jurisdiction. It must be reasonable or in other words it' must be based on reasons which are relevant and material". 5. In reply, counsel for revenue, submitted that the first respondent was not required to state reasons, while issuing Exts. P12&13. Existence of reason to believe that there was escapement of income is all that is needed to invoke the power under S.148, submits counsel. He relied on the decision in S. Narayanappa & Others v. The Commissioner of Incometax, Bangalore (AIR 1967 S.C. 523) to derive support for his submission. The court observed: "The earlier stage of the proceeding is for recording the reasons of the Incometax Officer and for obtaining the sanction of the Comissioner are administrative in character and are not quasi judicial. The scheme of S.34 of the Act is that, if the conditions of the main section are satisfied a notice has to be issued to the assessee containing all or any of the requirements there is no requirement in any of the provisions of the Act or any section laying down as a condition for the initiation of the proceedings that the reasons which induced the Commissioner to accord sanction to proceed under S.34 must also be communicated to the assessee". (emphasis supplied) To the same effect is the decision in Sowdagar Ahmed Khan v. Income-tax Officer, We/tore (1968) 70 ITR 79). (emphasis supplied) To the same effect is the decision in Sowdagar Ahmed Khan v. Income-tax Officer, We/tore (1968) 70 ITR 79). The Supreme Court found that initiation of proceedings under S.34(1)(a) (1922 act) would be valid, if material is available, to form 'the prima facie belief that assessee had omitted to disclose fully and truly all material facts'. 6. S.148 requires the Incometax Officer to record his reasons for issuing a notice for reopening an assessment. He is also required to serve a notice on the assessee in the manner contemplated by S.139(2). Under S.139(2) the Incometax Officer must 'issue and serve' a notice on the assessee to furnish a return of income. The section does not envision the need to disclose reasons for the belief, nor can it be read into it as a requirement of natural justice. No adjudication of rights, or determination resulting in consequences to the assessee is involved at the stage of issuing notice. The only requirement in law for initiating proceedings under S.148 is that there must be reasons to justify the belief that there is escapement and suppression of income. The requirement is only so far and no further, and the requirements of quasi judicial determination do not govern the proceedings at the stage of issuing a notice. Because no reasons are stated, it means not that there are no reasons. In the instant case, the files disclose that there are grounds for reasonable belief to initiate proceedings. Whether the reasons are sufficient to make an assessment or not, is a matter to be considered at a later stage, after considering' the case of the assessee and other relevant factors. 7. In the circumstances, there is no justification for quashing Exts. P12,13 or 16. However, the second respondent must consider Ext. P4 and pass orders thereon, within three months from today. Subject to this direction, the writ petition is dismissed.