Assessee, a non-resident, was appointed as a trustee for issuance of FBBCs of BFL (Indian company). Assessing Officer of assessee based on information received from Assessing Officer of payer, i.e. BFL, that interest/redemption premium paid to assessee was without deducting TDS, reopened assessment and recorded his reason to believe that income chargeable to tax had escaped assessment. Action of Assessing Officer of BFL to deduct tax at source on redemption premium was deleted by Tribunal holding that income had not arisen in India in hands of recipient/non-resident and, therefore, there was no obligation on part of BFL to deduct tax at source on payment of interest (redemption premium). Since material/information on which Assessing Officer had reopened assessment was removed, notice under section 148 would itself failed and action of Assessing Officer to reopen assessment was to be quashed. (AY. 2014-15)