Allowing the petition the Court held that the notice for reopening could not have been issued without there being any tangible material to come to the conclusion that there was escapement of income. There was no live link to form a belief, more particularly, when the Assessing Officer during the course of the original assessment had raised queries with regard to both the issues by issuing notices under section 142(1) of the Income-tax Act, 1961 which were duly replied by the assessee. Accordingly the notice to withdraw the claim allowed under section 80GGA read with section 35(1)(ii) of the Act  was quashed.(AY. 2013-14)