Allowing the petition the Court held that  AO wanted to verify the cash deposited in the bank account of the assessee by disregarding the explanation of the assessee on the ground that no prudent businessman will simply withdraw crores of cash from his bank account and again will deposit it at various stage. This is merely personal opinion of the AO. However, for the purpose of reopening an assessment there should be a tangible material placed by the assessing officer to show that there was escapement of income from the payment of income tax.  This being conspicuously absent, notice issued under section 148 of the Act is bad in law. (AY.2017-18)