Dismissing the petition the Court held that  though the Explanation to section 149 of the 1961 Act clarified that deposits in bank accounts formed a part of the assets of the assessee, the contentions of the assessee in respect of the expiry of limitation for issue of notice under section 148 of the 1961 Act was unsustainable since the amount of income of the assessee that had escaped assessment was a sum of Rs. 2,23,95,787 which was higher than the minimum threshold of Rs. 50 lakhs as stipulated under section 149 of the 1961 Act. The limitation for the initiation of reassessment proceedings would resultantly extend to ten years since the Assessing Officer had in his possession books of account of the assessee evidencing voluntary deposits in bank accounts extending to more than Rs. 50 lakhs. Therefore, the Assessing Officer had formed an opinion based on tangible and concrete information in the form of the assessee’s trust deed, the statement of the assessee’s managing trustee that certain identified foreign contributions received by the assessee were utilised for a purpose divergent to its object as disclosed in the trust deed, and accordingly, the wrongful application of the exemption availed of under section 11 or section 12 of the 1961 Act in relation to such funds and had resulted in the Assessing Officer forming the subjective satisfaction that the exemption of foreign contributions wrongly availed of was the escaped income under section 147. Court also held that   to invoke the jurisdiction of court under article 226 of the Constitution the individual must display bona fides. The assessee had suppressed material facts in relation to the cancellation of its registration under sections 12A, 12AA and 12AB of the 1961 Act. (AY.2016-17)