ORDER : AKIL KURESHI, J. 1. The petitioner has challenged a notice of reopening dated 27.03.2017 issued by the respondent-Assessing Officer. 2. Facts are as under. 3. Petitioner is an individual. For the assessment year 2010-11, the petitioner had filed the return of income on 20.09.2010 disclosing the total income which included short term capital gain on sale of land. Such return was accepted by the Revenue under section 143(1) without scrutiny. To reopen such assessment, the Assessing Officer issued the said notice. In order to do so, the Assessing Officer had recorded following reasons: “As per the AIR information it is found that for the F.Y. 2009-10 i.e. A.Y.2010-11 assessee had entered into sale of immovable properties of Rs.40,00,000/. Accordingly, letter has been issued to the assessee on 22/02/2017 for verification of transaction which has been duly served upon the assessee. In response to the same the assessee had furnished his reply. The sale transaction entered into by the assessee is required to be verified. In view of the above facts, I have reason to believe that income has escaped assessment to the extent of Rs.40,00,000/as stated above. As such assessment for A.Y. 2010-11 is require to be reopened in terms of provisions of Section 147 of the I.T. Act, 1961 by invoking the provisions of section 148 of the I.T. Act since there is an escapement of income within the meaning of section 147 of the Income Tax Act. In view of the same, I am reason to believe that income chargeable to tax has escaped assessment. And the same is fit case for issuing notice u/s.148 of the I.T. Act, 1961. Hence, notice u/s.148 is required to be issued in this case for A.Y. 2010-11.” 4. The assessee filed objections to the notice for reopening under letter dated 26.08.2017. Such objections were rejected by the Assessing Officer by an order dated 08.09.2017. Hence, this petition. 5. We have heard learned counsel for the parties. We are conscious that the assessee's original return was accepted without scrutiny. It was to reopen such assessment, the Assessing Officer has issued impugned notice. Such objections were rejected by the Assessing Officer by an order dated 08.09.2017. Hence, this petition. 5. We have heard learned counsel for the parties. We are conscious that the assessee's original return was accepted without scrutiny. It was to reopen such assessment, the Assessing Officer has issued impugned notice. We are conscious that in a case where no scrutiny assessment was previously framed and therefore no opinion formed by the Assessing Officer on any of the issues involved in the assessment, in the context of reopening of the assessment, the concept of change of opinion would not be relevant. Nevertheless, even in such a case it would not be open for the Assessing Officer to arbitrarily or to indiscriminately reopen the assessments. In such a case also, as held and observed by this Court in case of Inductotherm (India) P. Ltd. v. M. Gopalan, Deputy Commissioner of Income-Tax reported in [2013] 356 ITR 481 (Guj), the Assessing Officer must have reason to believe that income chargeable to tax has escaped assessment. This requirement of reason to believe would apply even in a case where the reopening of assessment is being resorted to where previously no scrutiny assessment was framed. In the context of such requirement of reason to believe, on number of occasions, this Court has held and declared that reopening of the assessment cannot be held for a fishing or a roving inquiry or for verification of the records. In case of Inductotherm (supra) itself this issue was highlighted. “18. Reverting to the facts of the present case, we notice that in two out of four reasons recorded by the Assessing Officer for reopening the assessment, he stated that he need to verify the claims. In the second ground, he had recorded that admissibility of the bad debts written off required to be verified. In the fourth ground also, he had recorded that admissibility of royalty claim was required to be verified. We are in agreement with the contention of the counsel for the petitioner that for mere verification of the claim, power for reopening of assessment could not be exercised. The Assessing Officer in guise of power to reopen an assessment, cannot seek to undertake a fishing or roving inquiry and seek to verify the claims as if it were a scrutiny assessment.” 6. The Assessing Officer in guise of power to reopen an assessment, cannot seek to undertake a fishing or roving inquiry and seek to verify the claims as if it were a scrutiny assessment.” 6. If one reverts back to the reasons recorded by the Assessing Officer for reopening the assessment, all that he has stated that the records suggest that the assessee has entered into sale transaction of the property of Rs.40,00,000/and the sale transaction entered into by the assessee is required to be verified. 7. In the result, impugned notice dated 27.03.2017 is set aside. Petition is allowed and disposed of accordingly.