Held, that the Assessing Officer had decided to reopen the completed assessment on the grounds of doubts on the correctness of losses claimed in the transactions carried out on the platform of the National Stock Exchange. The Assessing Officer had merely made averments towards the modus operandi used by different brokers for transfer of profit and loss of one constituent to another by modification of the client code but there was no reference to any relevant material which could give rise to prima facie belief of escapement resulting to the Revenue. There was no iota of reference to any transaction-wise detail where the client code of the assessee had undergone any modifications causing transfer of profits from the assessee to any other party or constituent. The name of the broker facilitating the client code modification was also not mentioned in the reasons recorded. There was no reference to any material providing foundation for holding belief. The instances of transactions resulting in loss or profit to the assessee on account of client code modification did not feature in the reasons at all. The Assessing Officer had proceeded on a hypothesis flowing from a generic information rendering the whole exercise to be arbitrary and unsustainable in law. The belief towards escapement was only pretence and a mere doubt and suspicion towards probable escapement though worded as “reasonable belief”. Therefore, the reassessment notice under section 148 is   quashed.(AY.2010-11)