JUDGMENT : A.J. Shastri, J. 1. The present petition contains a challenge to the legality and validity of the notice dated 31.3.2015 issued by the authority under Section 148 of the Income-Tax Act, 1961 (for short 'the Act') as also an order dated 21.1.2016 passed by the authority rejecting the objections filed by the petitioner. 2. Brief facts leading to the petition are summarized as under: 2.1 The petitioner is a limited company doing the business of manufacturing winding machines including cone winders, precision winders and versa winders and the petitioner is an income-tax assessee has submitted return of income for the Assessment Year 2012-13 declaring total income of Rs. 4,80,87,320/- along with Tax Audit Report and Form Nos. 3(c)(a) as also 3(c)(d) along with audited financial statement. The petitioner company received a notice under Section 143(2) of the Act dated 23.9.2013 and also received another notice under Section 142(1) dated 27.11.2014 along with questionnaire running into 20 questions calling for varied information. 2.2 The petitioner under a letter dated 12.12.2014 supplied the details called for by the respondent authority and extensive scrutiny is undertaken by the authority and in the said scrutiny assessment, an assessment order under Section 143(3) of the Act dated 3.10.2013 came to be passed accepting the total income written by the petitioner. 2.3 It is the case of the petitioner that subsequently, the petitioner received a notice under Section 148 of the Act dated 31.3.2015, inter-alia, stating that there is a reasonable belief of the authority that income chargeable to tax had escaped the assessment and thereby, asked the petitioner to submit the return in the prescribed form within 30 days. The petitioner under a letter dated 25.4.2015 submitted before the authority that return of the petitioner company had been thoroughly scrutinized and scrutiny assessment order also came to be passed and in the said letter, the petitioner has asked for the reasons which have been recorded while issuing notice under Section 148 of the Act so as to see that effective return of income can be submitted to apply the notice. In response to the notice of reassessment, petitioner filed its return on 28.4.2015 and under a letter dated 10.8.2015, the authority has submitted the copy of reasons which have been recorded and simultaneously, served notices under Sections 143(2) and 142(1) of the Act. In response to the notice of reassessment, petitioner filed its return on 28.4.2015 and under a letter dated 10.8.2015, the authority has submitted the copy of reasons which have been recorded and simultaneously, served notices under Sections 143(2) and 142(1) of the Act. The petitioner pursuant to it submitted the objection under a letter dated 24.8.2015, inter-alia, contending that the petitioner has fully and truly disclosed all material facts necessary for assessment and there is no failure on its part to do so. It was also contended that Investigating Wing has mechanically reproduced the reasons for reopening for the assessment which has been thoroughly scrutinized culminating into final scrutiny assessment order and therefore, it is the case of the petitioner while submitting objection that reopening under Section 148 of the Act is impermissible. Said letter of objection submitted by the petitioner came to be examined by the authority and vide order dated 21.1.2016, the authority, after considering the reasons which have been recorded as well as after considering the submissions made by the petitioner in its letter of objection, came to the conclusion that objections are not sustainable and therefore, rejected the same vide letter stated above. It is in this background of fact the petitioner has invoked extraordinary jurisdiction of this Court under Article 226 of the Constitution of India for challenging the legality and validity of the issuance of notice under Section 148 of the Act as also the order of rejection of objections submitted by the petitioner. 3. In the background of aforesaid fact, Mr. M.J. Shah, learned counsel appearing on behalf of the petitioner has submitted that notice for reopening served upon the petitioner is submitted after scrutiny assessment wherein, the petitioner has fully and truly disclosed all material relevant to the assessment and therefore, in view of the fact that once the scrutiny assessment has been undertaken, it is not open for the authority to re-examine by reopening the assessment. Learned counsel also contended before the Court that to arrive at a reasonable belief the reasons which are recorded are not valid reasons and there reflects no independent satisfaction arrived at by the authority. Learned counsel also contended before the Court that to arrive at a reasonable belief the reasons which are recorded are not valid reasons and there reflects no independent satisfaction arrived at by the authority. It is merely on the basis of some third party information, the authority has come to the conclusion that assessment which has become final deserves to be reopened and therefore, for forming a belief of reopening, no independent application of mind is reflecting. Learned counsel further submitted that TDS which has been deducted on the payments made and also the address, permanent account number and the amount of commission given to the party have been submitted before the Income-Tax Department at the time of previous scrutiny assessment and those materials have been examined in detail by the Assessing Officer and only thereafter, the scrutiny assessment culminated finally. It is in this background, learned counsel for the petitioner submitted that the information received by some another agency can never be a subject matter of reopening of assessment once having been finalized. Learned counsel also submitted that the order passed by the respondent authority rejecting the objections of the petitioner is also not in the right spirit nor in consonance with the decision reported in 259 ITR 19 and thereby, has submitted that reopening is not warranted. Learned counsel further submitted that if the executing authority is acting without jurisdiction or acting in a manner in which it is not permissible then, the High Court has ample power irrespective of alternative remedy to invoke extraordinary jurisdiction and to prohibit the authority from acting in the manner not in consonance with the law and thereby, requested the Court not to permit reopening of assessment once same has become final. No other submissions have been made. However, ultimately learned counsel for the petitioner submitted to set aside the impugned order rejecting the objections as well as notice issued under Section 148 of the Act. 4. As against this, Mr. Sudhir Mehta, learned counsel appearing on behalf of the Revenue has submitted that the authority is justified in reopening the assessment of the petitioner. The Assessing Authority, while issuing the notice under Section 148 of the Act, has enough material to substantiate the reopening and for forming a reasonable belief that income has escaped the assessment. As against this, Mr. Sudhir Mehta, learned counsel appearing on behalf of the Revenue has submitted that the authority is justified in reopening the assessment of the petitioner. The Assessing Authority, while issuing the notice under Section 148 of the Act, has enough material to substantiate the reopening and for forming a reasonable belief that income has escaped the assessment. It was submitted by learned counsel that a specific information has been received by the DGIT (Investigation), Ahmedabad on 26.3.2015 wherein, it is stated that two surveys were carried out by the I/o. Pr. DIT (Inv.) Kolkata on Vikrant Kayan and Arvind Kayan respectively and these Kayans were well known entry operators of Kolkata and have been indulging in entries of bogus share capital, bogus bill of expenses and bogus long term capital gain and the authority having realized this found live link, prima facie has opined that income of the petitioner has escaped assessment and therefore, such reasonable belief based upon justifiable material, cannot be examined in writ jurisdiction. Learned counsel for the Revenue submitted that for forming an opinion and to come to a reasonable belief, the Assessing Officer is not ascertaining finally the fact of legal evidence or conclusion. The function of the Assessing Officer is to administer the statute with solicitude for the public exchange with an inbuilt idea of fairness to tax payer as well and therefore, at the initial stage, what is required is reason to believe but, not established fact of escapement of income and therefore, at this stage of issuance of notice, only question to be dealt with by Assessing Authority is whether there is any relevant material on which a reasonable person could have formed a reasonable belief and therefore, since this is merely a stage where a reasonable belief is formed, the authority may not be allowed to be intercepted in exercise of its statutory function and thereby learned counsel for the Revenue submitted that no interference be made in exercise of writ jurisdiction. 5. Having heard learned counsel appearing for the respective parties, before dealing with the submissions made before the Court, first and foremost consideration to deal with is as to whether a reasonable belief formed by the authority is based upon some material or not. 5. Having heard learned counsel appearing for the respective parties, before dealing with the submissions made before the Court, first and foremost consideration to deal with is as to whether a reasonable belief formed by the authority is based upon some material or not. To deal with this, we may reproduce the reasons which are recorded by the authority while issuing notice under Section 148 of the Act. Relevant extract of the said reasons read as under: "3. The assessee is engaged in the business of manufacturing of textile machinery and spare parts. The assessee has filed his return of income on 4.2.2014 declaring total income at Rs. 4,80,87,320/-. The case was selected for scrutiny and assessment was completed u/s. 143(2) dated 23.2.2015 accepting return of income. 4. In this case, information has been received by DGIT (Investigation), Ahmedabad vide No. DGIT(Inv.)/AHD/VAT/Bogus Purchase/2014-15 dated 26.3.2015. It is stated in the letter that two surveys were carried out by the Pr. DIT (Inv.) Kolkata on Vikrant Kayan and Arvind Kayan respectively. The Kayans are known entry operators of Kolkata and have been giving entries of bogus share capital, bogus bills of expenses and bogus long term capital gains to various beneficiaries through out the country. The above mentioned assessee is also a beneficiary of Rs. 181,93 lacs (accommodating co. Tafford Fleur Pvt. Ltd.) pertaining to A.Y. 2012-13. 5. Considering the facts stated above. I have reason to believe that the income". 6. Perusal of the said reasons postulate that an information has been received by DGIT (Inv.) branch of Ahmedabad about bogus purchases wherein, it has been emerged that two survey operations were carried out by the competent authority, Kolkata in case of Vikrant Kayan and Arvind Kayan and the information which has been gathered is that these Kayans are well known entry operators of Kolkata and have been giving entries of bogus share capital, bogus billing entries pertaining and bogus long term capital gains to various beneficiaries across the country and it has been revealed in the said information that this very assessee i.e. present petitioner is also a beneficiary of such entry operation of Kayans to the extent of Rs. 127.94 lacs (accommodating co. 127.94 lacs (accommodating co. Agnes Bruno Ltd.) pertaining to A.Y. 2008-09 and based upon this material, the authority has issued notice under Section 148 of the Act for reopening of assessment as from the material, the authority found that there is a reasonable belief that income of the petitioner - assessee has escaped assessment and therefore, it is justified to reopen the assessment. 7. It is also emerging from the order passed by the authority rejecting the objections submitted by the petitioner dated 21.1.2016 that each and every material submitted by the petitioner has been extensively dealt with and a detailed order came to be passed and the said order is supported by cogent reasons, the decision arrived at to reopen the assessment appears to be just and proper. From the material available, the authority prima facie found that petitioner - assessee is also the beneficiary of those Kayans brothers, who are well known entry operators across the country and to the extent of sizable amount, the petitioner has also been benefited and this part of the income appears to have been escaped assessment in the belief of the authority, the said belief cannot intercepted by exercising extraordinary jurisdiction of this Court under Article 226 of the Constitution of India. 8. In the background of aforesaid circumstance available and reflected on record, it appears to this Court that the authority has applied its mind and has rightly relied upon the information available before it while exercising the power to reopen the assessment. We may recall the proposition of law on the issue in question in a well known decision of Apex Court in case of Assistant Commissioner of Income-Tax Vs. Rajesh Jhaveri Stock Brokers Pvt. Ltd., reported in 2007 (291) ITR 500 . The Apex Court, dealing with the said case, has dealt with statutory provisions prior to amendment as well as post amendment and after analyzing the provisions of Sections 147 and 148 of the Act, the Apex Court has opined that Section 147 authorizes and permits the Assessing Officer to assess or re-assess the income chargeable to tax if he has reason to believe that income for any assessment year as escaped the assessment. The word 'reason' in the phrase 'reason to believe' would mean cause or justification and after considering and analyzing the provision, it has been propounded that the expression cannot be read to mean that Assessing Officer should have finally ascertained the fact of legal evidence or conclusion. At the initial stage what is required is reason to believe but, not established fact of escapement of income and therefore, at this stage only question whether there was relevant material to form a reasonable belief is to be seen and in the background of present facts, there is a specific information received about the Kayans brothers during investigation by the authority and it has been prima facie found that present petitioner - assessee is also the beneficiary of the said Kayan brothers. At this stage of the proceeding, the factum of said aspect whether the petitioner is beneficiary or not, is not to be finally adjudicated upon by the Assessing Officer and therefore, this Court is not in a position to dwell into it but, only has to examine whether there is a reasonable belief arrived at or not and from the basis of aforesaid circumstance prevailing on record, it appears that the Assessing Officer is justified prima facie in arriving at conclusion to reopen the assessment. A liberty is always available to the petitioner to justify or to deal with the same, but this is not the stage where the process of reopening based upon aforesaid material is to be intercepted. The relevant extract contained in the said decision of the Apex Court is reproduced hereinafter: "16. Section 147 authorises and permits the Assessing Officer to assess or reassess income chargeable to tax if he has reason to believe that income for any assessment year has escaped assessment. The word reason in the phrase reason to believe would mean cause or justification. If the Assessing Officer has cause or justification to know or suppose that income had escaped assessment, it can be said to have reason to believe that an income had escaped assessment. The expression cannot be read to mean that the Assessing Officer should have finally ascertained the fact by legal evidence or conclusion. The function of the Assessing Officer is to administer the statute with solicitude for the public exchequer with an inbuilt idea of fairness to taxpayers. The expression cannot be read to mean that the Assessing Officer should have finally ascertained the fact by legal evidence or conclusion. The function of the Assessing Officer is to administer the statute with solicitude for the public exchequer with an inbuilt idea of fairness to taxpayers. As observed by the Delhi High Court in Central Provinces Manganese Ore Co. Ltd. [ 1991 (191) ITR 662 ], for initiation of action under section 147(a) (as the provision stood at the relevant time) fulfillment of the two requisite conditions in that regard is essential. At that stage, the final outcome of the proceeding is not relevant. In other words, at the initiation stage, what is required is reason to believe, but not the established fact of escapement of income. At the stage of issue of notice, the only question is whether there was relevant material on which a reasonable person could have formed a requisite belief. Whether the materials would conclusively prove the escapement is not the concern at that stage. This is so because the formation of belief by the Assessing Officer is within the realm of subjective satisfaction (see ITO v. Selected Dalurband Coal Co. Pvt. Ltd. [ 1996 (217) ITR 597 (SC)]; Raymond Wollen Mills Ltd. v. ITO [1999 (236) ITR 34 (SC)]. 17. The scope and effect of section 147 as substituted with effect from April 1, 1989, as also sections 148 to 152 are substantially different from the provisions as they stood prior to such substitution. Under the old provisions of section 147, separate clauses (a) and (b) laid down the circumstances under which income escaping assessment for the past assessment years could be assessed or reassessed. To confer jurisdiction under section 147(a) two conditions were required to be satisfied firstly the Assessing Officer must have reason to believe that income profits or gains chargeable to income tax have escaped assessment, and secondly he must also have reason to believe that such escapement has occurred by reason of either (i) omission or failure on the part of the assessee to disclose fully or truly all material facts necessary for his assessment of that year. Both these conditions were conditions precedent to be satisfied before the Assessing Officer could have jurisdiction to issue notice under section 148 read with section 147(a) But under the substituted section 147 existence of only the first condition suffices. Both these conditions were conditions precedent to be satisfied before the Assessing Officer could have jurisdiction to issue notice under section 148 read with section 147(a) But under the substituted section 147 existence of only the first condition suffices. In other words if the Assessing Officer for whatever reason has reason to believe that income has escaped assessment it confers jurisdiction to reopen the assessment. It is however to be noted that both the conditions must be fulfilled if the case falls within the ambit of the proviso to section 147. The case at hand is covered by the main provision and not the proviso. 18. So long as the ingredients of section 147 are fulfilled, the Assessing Officer is free to initiate proceeding under section 147 and failure to take steps under section 143(3) will not render the Assessing Officer powerless to initiate reassessment proceedings even when intimation under section 143(1) had been issued." 9. In another case recently being dealt with by this Court in a group of tax appeals being Tax Appeal Nos. 542 of 2015 and allied matters wherein, very issue whether at the instance of same material of another wing, whether reopening is permissible or not. While dealing with said issue this Court has examined the said aspect and has come to the conclusion that reopening is permissible. In the said group of appeals, the substantial question of law posed before the Court, whether the ITAT was justified in setting aside the reassessment orders on the ground that reopening of assessment under Section 147 of the Act was bad in law. In that particular group of matters, the reopening was admitted by the authority based upon the show cause notice along with accompanied material forwarded by the Excise Department to the Income-Tax Department and on the basis of said material provided by the Excise Department, the Assessing Officer has reopened the assessment of the assessee by issuing notice under Section 148 of the Act. The assessee of that case in the similar manner in this case has contended that the information provided by a different Investigating Team may not be ipso facto utilized to re open the assessment which has become final by the Income-tax authority. The assessee of that case in the similar manner in this case has contended that the information provided by a different Investigating Team may not be ipso facto utilized to re open the assessment which has become final by the Income-tax authority. It was also contended by the assessee of that case that there was no independent application of mind on the part of Assessing Officer and just based upon said information provided by the Excise Department, the authority resorted to Section 148 of the Act to reopen the assessment. This issue in extenso dealt with by the Division Bench of this Court and by a detailed judgment, came to conclusion that the Assessing Officer has merely relied upon the show cause notice issued by the Excise Department and has not concluded finally and therefore, there is no illegality or irregularity in arriving at a belief that assessment deserves to be reopen. Relying upon the decision delivered by the Apex Court, it is held that action of reopening of assessment was found to be justified. Relevant Paragraph Nos. 9, 10, 11, 12, 13 and 16 of the said decision worth to be taken note of and therefore, reproduced hereinbelow: "9. It can thus be seen that the entire material collected by the DGCEI during the search, which included incriminating documents and other such relevant materials, was alongwith report and show-cause notice placed at the disposal of the Assessing Officer. These materials prima facie suggested suppression of sale consideration of the tiles manufactured by the assessee to evade excise duty. On the basis of such material, the Assessing Officer also formed a belief that income chargeable to tax had also escaped assessment. When thus the Assessing officer had such material available with him which he perused, considered, applied his mind and recorded the finding of belief that income chargeable to tax had escaped assessment, the re-opening could not and should not have been declared as invalid, on the ground that he proceeded on the show-cause notice issued by the Excise Department which had yet not culminated into final order. At this stage the Assessing Officer was not required to hold conclusively that additions invariably be made. He truly had to form a bona fide belief that income had escaped assessment. In this context, we may refer to various decisions cited by the counsel for the Revenue. 10. At this stage the Assessing Officer was not required to hold conclusively that additions invariably be made. He truly had to form a bona fide belief that income had escaped assessment. In this context, we may refer to various decisions cited by the counsel for the Revenue. 10. In case of Central Provinces Manganese Ore Co. Ltd. vs. Income Tax Officer, Nagpur (supra) the Supreme Court noted that in case of the assessee which had an office in London, this Customs authority had come to know that the assessee had declared very low price in respect of the consignment of Manganese exported by them out of India. After due inquiries and investigations, the Customs authorities found that the assessee was systematically under-voicing the value of Manganese as compared with the prevailing market price. The Income Tax Officer on coming to know about the proceedings before the Customs Collector in this respect issued notice for reopening of the assessment. In the reasons that the Assessing Officer relied on the facts as found by the Customs Authorities that the assessee had under-voiced goods during export. Under such circumstances, upholding the validity of the notice for reopening, the Supreme Court held and observed as under: 'So far as the first condition is concerned, the Income Tax Officer, in his recorded reasons, has relied upon the fact as found by the Customs Authorities that the appellant had under invoiced the goods it exported. It is not doubt correct that the said finding may not be binding upon the income tax authorities but it can be a valid reason to believe that the chargeable income has been under assessed. The final outcome of the proceedings is not relevant. What is relevant is the existence of reasons to make the Income Tax Officer believe that there has been under assessment of the assessee's income for a particular year. We are satisfied that the first condition to invoke the jurisdiction of the Income Tax Officer under Section 147(a) of the Act was satisfied.' 11. What is relevant is the existence of reasons to make the Income Tax Officer believe that there has been under assessment of the assessee's income for a particular year. We are satisfied that the first condition to invoke the jurisdiction of the Income Tax Officer under Section 147(a) of the Act was satisfied.' 11. In case of Income Tax Officer vs. Purushottam Das Bangur (supra) after completion of assessment in case of the assessee, the Assessing Officer received letter from Directorate of Investigation giving detailed particulars collected from Bombay Stock Exchange which revealed earning of share and price of share increased during period in question and quotation appearing at Calcutta Stock Exchange was as a result of manipulated transaction. On the basis of such information, the Assessing Officer issued notice for reopening of the assessment. The question, therefore, arose whether the information contained in the letter of Directorate of Investigation could be said to be definite information and the Assessing Officer could act upon such information for taking action under Section 147(b) of the Act. In such background, the Supreme Court observed as under: '12. Ms. Gauri Rastogi, the learned appearing for the respondents, has urged that the letter of Shri Bagai was received by the Income tax Officer on March 26, 1974 and on the very next day, that is, on March 27, 1974, he issued the impugned notice under Section 147(b) of the Act and that he did not have conducted any inquiry or investigation into the information sent by Shri Bagai. Merely because the impugned notice was sent on the next day after receipt of the letter of Shri Bagai does not mean that the Income Tax Officer did not apply his mind to the information contained in the said letter of Shri Bagai. On the basis of the said facts and information contained in the said letter, the Income Tax officer, without any further investigation, could have formed the opinion that there was reason to believe that the income of the assessee chargeable to tax had escaped assessment. The High Court, in our opinion, was in error in proceeding on the basis that it could not be said that the Income Tax Officer had in his possession information on the basis of which he could have reasons to believe that income of the assessee chargeable to tax had escaped assessment for the relevant assessment years. The High Court, in our opinion, was in error in proceeding on the basis that it could not be said that the Income Tax Officer had in his possession information on the basis of which he could have reasons to believe that income of the assessee chargeable to tax had escaped assessment for the relevant assessment years. For the reasons aforementioned, we are unable to uphold the impugned judgment of the High Court. The appeal is, therefore, allowed, the impugned judgment of the High Court is set aside and the Writ Petitions filed by the respondents are dismissed. No order as to costs.' 12. In case of Income Tax Officer vs. Selected Dalurband Coal Co. Pvt. Ltd. (supra), the assessment was reopened on the basis of the information contained in letter from Chief Mining Officer that the colliery of the assessee had been inspected and there had been under reporting of coal raised. Upholding the validity of reopening of assessment, the Supreme Court held and observed as under: 'After hearing the learned counsel for the parties at length, we are of the opinion that we cannot say that the letter aforesaid does not constitute relevant material or that on that basis, the Income Tax Officer could not have reasonably formed the requisite belief. The letter shows that a joint inspection was conducted in the colliery of the respondent on January 9, 1967, by the officers of the Mining Department in the presence of the representatives of the assessee and according to the opinion of the officers of the Mining Department, there was under reporting of the raising figure to the extent indicated in the said letter. The report is made by a Government Department and that too after conducting a joint inspection. It gives a reasonably specific estimate of the excessive coal mining said to have been done by the respondent over and above the figure disclosed by it in its returns. Whether the facts stated in the letter are true or not is not the concern at this stage. It may be well be that the assessee may be able to establish that the facts stated in the said letter are not true but that conclusion can be arrived at only after making the necessary enquiry. Whether the facts stated in the letter are true or not is not the concern at this stage. It may be well be that the assessee may be able to establish that the facts stated in the said letter are not true but that conclusion can be arrived at only after making the necessary enquiry. At the stage of the issuance of the notice, the only question is whether there was relevant material, as stated above, on which a reasonable person could have formed the requisite belief. Since we are unable to say that the said letter could not have constituted the basis for forming such a belief, it cannot be said that the issuance of notice was invalid. Inasmuch as, as a result of our order, the reassessment proceedings have not to go on we don not and we ought not to express any opinion on the merits.' 13. In case of AGR Investment Ltd. vs. Additional Commissioner of Income Tax and Anr. (supra), a Division Bench of Delhi High Court considered the validity of reopening of assessment where the notice was based on information received from Directorate of investigation that the assessee was beneficiary of bogus accommodation entries. The Court while upholding the validity of reopening observed that sufficiency of reason cannot be considered in a writ petition. It was observed as under: '23. The present factual canvas has to be scrutinized on the touchstone of the aforesaid enunciation of law. It is worth noting that the learned counsel for the petitioner has submitted with immense vehemence that the petitioner had entered into correspondence to have the documents but the assessing officer treated them as objections and made a communication. However, on a scrutiny of the order, it is perceivable that the authority has passed the order dealing with the objections in a very careful and studied manner. He has taken note of the fact that transactions involving Rs. 27 lakhs mentioned in the table in Annexure P-2 constitute fresh information in respect of the assessee as a beneficiary of bogus accommodation entries provided to it and represents the undisclosed income. The assessing officer has referred to the subsequent information and adverted to the concept of true and full disclosure of facts. 27 lakhs mentioned in the table in Annexure P-2 constitute fresh information in respect of the assessee as a beneficiary of bogus accommodation entries provided to it and represents the undisclosed income. The assessing officer has referred to the subsequent information and adverted to the concept of true and full disclosure of facts. It is also noticeable that there was specific information received from the office of the DIT (INV-V) as regards the transactions entered into by the assessee company with number of concerns which had made accommodation entries and they were not genuine transactions. As we perceive, it is neither a change of opinion nor does it convey a particular interpretation of a specific provision which was done in a particular manner in the original assessment and sought to be done in a different manner in the proceeding under Section 147 of the Act. The reason to believe has been appropriately understood by the assessing officer and there is material on the basis of which the notice was issued. As has been held in Phool Chand Bajrang Lal (supra), Bombay Pharma Products (supra) and Anant Kumar Saharia (supra), the Court, in exercise of jurisdiction under Article 226 of the Constitution of India pertaining to sufficiency of reasons for formation of the belief, cannot interfere. The same is not to be judged at that stage. In SFIL Stock Broking Ltd. (supra), the bench has interfered as it was not discernible whether the assessing officer had applied his mind to the information and independently arrived at a belief on the basis of material which he had before him that the income had escaped assessment. In our considered opinion, the decision rendered therein is not applicable to the factual matrix in the case at hand. In the case of Sarthak Securities Co. Pvt. Ltd. (supra), the Division Bench had noted that certain companies were used as conduits but the assessee had, at the stage of original assessment, furnished the names of the companies with which it had entered into transactions and the assessing officer was made aware of the situation and further the reason recorded does not indicate application of mind. That apart, the existence of the companies was not disputed and the companies had bank accounts and payments were made to the assessee company through the banking channel. Regard being had to the aforesaid fact situation, this Court had interfered. That apart, the existence of the companies was not disputed and the companies had bank accounts and payments were made to the assessee company through the banking channel. Regard being had to the aforesaid fact situation, this Court had interfered. Thus, the said decision is also distinguishable on the factual score.' 16. Thus, the decision in case of Futura Ceramics Pvt. Ltd. And Anr. vs. State of Gujarat through Secretary and Ors. (supra) was rendered in an entirely different background and had no direct application to the question whether on the basis of information supplied by the Excise Department to the Assessing Officer of suppression of valuation of goods or clandestine removal of goods for evading excise duty, notice for re-opening of the assessment could have been issued." 10. Considering the aforesaid situation prevailing on record, it appears to this Court that the background of facts demand reopening of assessment and the authority is justified in issuing notice under Section 148 of the Act and the reasons based upon it are sufficient enough to permit the authority to exercise jurisdiction to reopen the assessment. Even from bare reading of the order rejecting the objections also, appear to this Court cogent enough as supported by valid reasons. The same is also not required to be interfered with. Hence, the present petition deserves to be dismissed and accordingly, it is dismissed. Notice is discharged. Interim relief, if any, granted earlier stands vacated.