On basis of information that assessee had received loan from its 100 per cent subsidiary and said issue was not examined during assessment proceedings, notice under section 148A(b) was issued to assessee. In response to notice under section 148A(b), assessee submitted that during year relevant to assessment year, it had received no loans rather repayment had been made of advance received earlier.  Assessing Officer in order passed under section 148A(d) considered reply of assessee and had found it tenable and observed that assessee had not provided any evidences with regard to source of funds utilized for making payment of loan and he, thus, treated loan repayment amount as income and made addition to income of assessee.On writ the Court held that the Assessing Officer could not supplement or improve upon reason which formed basis for initiating action under section 148A. Explanation  3 of section 147 can be applied only where power to reassess is validly invoked.    Since foundational material alone would be relevant for purposes of evaluating whether reassessment powers were justifiably invoked,  reassessment proceedings were  quashed and set aside. (AY. 2014-15 to 2016-17)