JUDGMENT : Govind Mathur, J. 1. These appeals are before us to examine correctness of the judgment dated 11.4.2014, passed by learned Single Bench in batch of writ petitions led by SB Civil Writ Petition No.1140/2014, Mukesh Modi v. Dy. Commissioner of Income Tax, Jodhpur. By the judgment impugned learned Single Bench, while accepting the petitions for writ, quashed the notices issued under Section 147/148 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act of 1961’) to the petitioner assessees. As per learned Single Bench the expression ‘reason to believe’ as referred under Section 148 of the Act of 1961 means the existence of rational and intelligible nexus between the reasons and the belief, so that on such reason no one properly instructed on facts and the law could reasonably entertain the belief. On basis of this ratio learned Single Bench held that while issuing the notices under Section 147/148 of the Act of 1961 the Assessing Officer had no reason to believe that any income chargeable to tax has escaped assessment for the assessment year and the Assessing Officer simply for his own verification and to clear his doubts and suspicion initiated the proceedings impugned. 2. We are in complete agreement with the interpretation accepted by learned Single Bench pertaining to the expression ‘reason to believe’ and on basis of that only we too have examined validity of the notices in question. Before coming to that, it would be appropriate to mention certain necessary facts in brief. 3. A search as per Section 132 of the Act of 1961 and survey under Section 133-A were simultaneously conducted by the investigation wing of the Income Tax Department at the business/residential premises of Modi @ Adarsh Group of Sirohi. Petitioners Mukesh Modi, Daksha Kumari Jain and Bharat Das Vaishnav were eventually covered under the search action and the survey was conducted relating to Prakash Beverages, Nakoda Land Developers and Sambhav Energy. During the course of search and survey certain documents/loose papers were seized and impounded. The entire process of search and survey was carried out on 10.2.2010 and on 6.1.2011 a notice under Section 153-A of the Act of 1961 was issued to petitioners Mukesh Modi, Daksha Kumari Jain and Bharat Das Vaishnav. During the course of search and survey certain documents/loose papers were seized and impounded. The entire process of search and survey was carried out on 10.2.2010 and on 6.1.2011 a notice under Section 153-A of the Act of 1961 was issued to petitioners Mukesh Modi, Daksha Kumari Jain and Bharat Das Vaishnav. A notice under Section 153 of the Act of 1961 was issued to Krishna Dairy by placing reliance upon certain documents found during the course of search. While undertaking proceedings under Section 153-A of the Act of 1961 the Assessing Officer scrutinised the material seized during the course of search and survey and after consideration of the same issued a consolidated questionnaire to the assessees concerned. On 23.12.2011 the assessment under Section 153-A read with Section 143(3) of the Act of 1961 came to be completed by making certain additions of income tax in the hands of Mukesh Modi, Daksha Kumari Jain and Bharat Das Vaishnav. The assessments made by the Assessing Officer as above are admittedly subject matter of appeals said to be pending before the Commissioner of Income Tax (Appeals). The Assessing Officer on 22.3.2013, while recording reasons to reopen the assessment under Section 147 of the Act of 1961, issued notices under Section 148 of the Act of 1961. While giving challenge to the notices aforesaid the petitioners contended that no cogent reasons were recorded by the Assessing Officer and whatever reasons recorded suggest that the Assessing Officer has assumed jurisdiction to initiate reassessment proceedings on its mere ipse dixit to clear suspicions and for verification. It is also important to mention that the respondent petitioners responded the notice dated 22.3.2013 on 31.5.2013 with following preliminary objections:- “(a). The condition precedent for Section 147 is that there must be a “reason to believe that income chargeable to tax has escaped assessment” and the belief entertained by ITO must not be arbitrary or irrational. (b). It must be based on objective reasons which are relevant and material. The belief must be in good faith and not merely be pretence. (c). The act of ITO must be based on evidence and not on mere suspicion, imagination and speculation. (d). In addition to above requirements there should be some direct nexus between the information in possession and conclusion drawn by the authority concerned and any conclusion based on any irrelevant and extraneous material would vitiate its effect. (e). (c). The act of ITO must be based on evidence and not on mere suspicion, imagination and speculation. (d). In addition to above requirements there should be some direct nexus between the information in possession and conclusion drawn by the authority concerned and any conclusion based on any irrelevant and extraneous material would vitiate its effect. (e). There has to be fresh material/information in possession of assessing authorities for the purpose of formation of belief that income of any particular assessment year has escaped assessment. (f). The burden is on the revenue to establish that there was income chargeable to tax, which has escaped assessment.” 4. As already stated, learned Single Bench accepted the version advanced by the assessee with specific finding that the notices issued under Section 147/148 of the Act of 1961 are not satisfying the pre-requisites as prescribed. 5. To examine the entire issue, we have looked into the notices issued under Section 147/148 of the Act of 1961. The Assessing Officer, at the threshold, noticed that during the course of search several incriminating documents along with cash, jewellery and other valuables were found and seized from various premises of the group concerned. During the course of survey an inventory of the consumable items, details of bank accounts, cheque books found, was also prepared. The material made available was not matched by the survey team as the same were not verifiable from the records. He also noticed that the cheque books, bank accounts etc. were belonging to various persons which are not connected with day to day business affairs of the assessee. The Assessing Officer also provided necessary details relating to dummy bills which were not taken into account earlier. By providing all necessary details the Assessing Officer recorded that he had reason to believe that the amount of Rs.10,37,22,520/- and various other amounts chargeable to tax escaped during the assessment for the account year 2010-11. 6. From perusal of the notice, it is apparent that the reason to believe that the income chargeable to tax has escaped assessment, is not mere suspicion but is based on good faith. The Assessing Officer has given complete details of the documents which were not taken into consideration earlier. The documents referred in the notice are also sufficient to show the direct nexus between the information in possession and conclusion withdrawn by the Assessing Officer. The Assessing Officer has given complete details of the documents which were not taken into consideration earlier. The documents referred in the notice are also sufficient to show the direct nexus between the information in possession and conclusion withdrawn by the Assessing Officer. The Assessing Officer though was not having fresh material for the purpose of formation to believe that the income of any particular assessment year has escaped assessment, but with all bonafides he noticed that certain documents escaped consideration and that resulted into escape of income chargeable to tax. 7. Learned Single Bench in detail has considered the entire law relating to pre-conditions for reassessment under Section 147/148 of the Act of 1961, but in our considered opinion has not looked into the notices under Section 148 of the Act of 1961 so minutely. Paras 3, 4, 5, 6, 7, 8 and 9 of the notice in specific terms indicate the material to arrive at a conclusion to have bona fide belief that a huge part of income which may be chargeable to tax was escaped. Looking to the document aforesaid we are of considered opinion that the Assessing Officer had adequate reason to believe to issue notice under Section 148 of the Act of 1961. Learned Single Bench failed to appreciate the notice concerned in light of the scope and spirit of the preconditions for issuing a notice under Section 148 of the Act of 1961. 8. The appeals, thus, deserves acceptance, hence, are allowed. The judgment impugned dated 11.4.2014, passed by learned Single Bench, is set aside. The writ petitions preferred by the petitioner respondents are dismissed.