Assessee-company is  engaged in business of real estate development and running of hotels.  During original assessment proceedings, assessment was framed at a total income as against declared income of assessee.  Subsequently, Assessing Officer received a valuation cell report from District Valuation Officer (DVO) with respect to cost of property.  After perusal of valuation report, it was found that DVO had estimated investment which were made by assessee in renovation/ reconstruction of property, furthermore report also mentioned, that assessee had declared total investment as nil.Assessing Officer issued reopening notice on ground that income had escaped assessment. On writ the Court held that   sole ground for reopening was valuation report, even though, assessee had declared cost of said property under head Fixed Assets and Capital WIP. Also there was no statement or discussion by Assessing Officer as to what was basis and why he should rely on valuation report. Since reasons for reopening of assessment did not reflect that Assessing Officer had applied his mind to ascertain as to whether in fact assessee had already declared value of aforesaid property under Fixed Assets and Capital WIP or whether such valuation is  correct or not. Reassessment notice and order disposing the objection is quashed. (AY. 2010-11, 2011-12)