The assessee explained that the cash deposited in his bank account represented redeposit of earlier cash withdrawals. The Assessing Officer rejected the explanation, whereas the Commissioner (Appeals) held that no supporting evidence had been produced. The Tribunal observed that there was only a short gap between the withdrawals and redeposits and that contradictory findings had been recorded regarding the availability of cash. Since the Assessing Officer had not established utilisation of the withdrawals for any other purpose, the matter was restored to the Commissioner (Appeals) for fresh examination in accordance with law. The assessee challenged the reassessment contending that it was based only on suspicion and not on a valid “reason to believe”. The Tribunal held that at the stage of initiation of reassessment proceedings, the Assessing Officer is only required to form a prima facie belief regarding escapement of income. Sufficiency of the material cannot be examined at that stage. Accordingly, the challenge to the reopening was rejected. Delay of six days in filing of appeal was condoned.   (AY. 2016-17).