The Assessing Officer must have some material and the material must be reliable before reopening the assessment. The valuation of the sub-registrar on spot verification showing an increase in the value of property for the purpose of addition under Section 50C of the Act is not supported by any revaluation order and no reference is made by the Director of Stamps to the sub-registrar and therefore no addition can be made There was  complete absence of any  information  or any material for formation of belief that the income of the assessee has escaped assessment prior to recording of reasons and issuance of notice u/s 148  of the Act, therefore the reassessment was held to be bad in law. (AY. 2009-2010)