Allowing the petition the Court held, that the case of the assessee was selected for scrutiny and detailed notice under section 142(1) of the Income-tax Act, 1961 was issued, requiring the assessee to furnish various details with respect to break-up of “any other amount allowable as deduction” claimed in Schedule BP of the return, wherein notional guarantee commission was claimed. The assessee submitted the requisite details. Thereafter, the assessment order under section 143(3) of the Act was passed. It is a settled legal position that reopening on the basis of audit party objections is invalid and on a bare perusal of the reasons recorded, it was apparent that there was no material available with the Assessing Officer to form a reason to believe that the income had escaped assessment. In such circumstances, the notice issued under section 148 was not valid.( AY. 2017-18)