Dismissing the petition the Court held that  the Assessing Officer had stated in the reasons for issue of the notice of reassessment that during the course of search operations in SPIL it had been found that various concerns of the group including the assessee were not genuine. The Department conducted a very detailed and thorough investigation, evidence was gathered, a large number of persons were examined, and a huge amount of hard and soft data was looked into. The assessee had not shown any business activity for the relevant year and had not filed any audited account before the Income-tax Department, at least till the time of initiation of the proceedings under section 147 and had filed only its Income-tax return. It was prima facie established that the assessee was a dummy company. The reasons recorded in the matter were communicated to the assessee. The objections of the assessee had been properly dealt with and it was not a case of mere suspicion. It was a case wherein the competent authority had reason to believe to reopen the assessment. There was specific information available with the authorities. The reasons to believe had been properly understood by the authorities and there was material on the basis of which notice was issued. The notice was valid. (AY. 2011-12)