For AYs 2001-02 to 2003-04, the AO reopened assessment on the basis of a DVO’s report obtained during a survey under section 133A, showing large differences between declared and actual construction costs of a nursing home and residential unit. The assessee challenged reopening as without jurisdiction. Held, dismissing the petition, that where undervaluation of income is found, AO has power to refer matter to DVO under section 131. The DVO’s report constituted tangible material justifying reopening under section 147. The AO had recorded proper reasons and rejected objections by a speaking order. Thus, reopening was valid. (AY. 2001-02 to 2003-04)