Assessee engaged in business of civil contract work. Assessee’s firm was converted into a private company. Subsequently, notice under section 148 of the Act was issued in the name of the firm which was not in existence on the date of the notice. Reasons recorded that assessee received Rs. 30cr from PACL for developing land. However, subsequently the reasons recorded a changed amount of Rs. 15cr admittedly the correct amount showing a casual manner in which alleged reasons were recorded for reopening. Tribunal held that the reasons recorded did not contain reason to believe under section 147 and could not justify reopening of assessment after lapse of several years. Reopening was bad in law as there was no material before the AO to show that expenses claimed were not allowable as the receipt of 15cr was disclosed in the return. The reopening was held invalid.  (AY. 2012-13)