Petitioners purchased bungalows in a scheme. A search under section 132 was conducted upon one Dr. Dilip Amabalal Modi, wherein loose papers were found and seized, which contained handwritten details of financial transactions of property situated at various places along with bifurcation of cheque and cash payments. On the basis, the Assessing Officer issued a reopening notice against petitioners on the ground that they had made cash payments over and above the sale consideration for the purchase of bungalows. On writ the Court held that the Assessing Officer had no other material except seized material which was found during search of residential premises of Dr. Dilip Amabalal Modi and on basis of such information, Assessing Officer had arrived at a prima-facie conclusion that petitioners would have also made payment of on-money over and above sale consideration reflected in sale deed without taking into consideration that each transaction made by petitioner was much earlier than that of transactions of purchase of Bungalow No. 6 made by Dr. Dilip Amabalal Modi  in year 2021-22, just prior to search carried out on 16-11-2021. Reliance placed on information found from the public domain was also without any basis, as the Assessing Officer could not have assumed jurisdiction on the basis of such information, which had no live nexus with material available on record in the form of a sale deed, which was executed by the petitioners much prior to the date of search. Valuation report of DVO could never have been the basis for assuming jurisdiction, as the valuation report was only an opinion of the valuer and the same was required to be supported by corroborative evidence to prima facie come to the conclusion that the petitioners must have paid on-money for the purchase of the bungalow. Notices being issued only for the purpose of making a fishing inquiry were quashed and set aside. (AY. 2019-20 to 2021-22)