Held that the reasons recorded for the formation of belief of escapement of income chargeable to Income-tax for the reopening of the completed assessment were found to be based on wrong and irrelevant facts, borrowed satisfaction and violation of principles of natural justice and were unsustainable,That whether assessment should have been completed under section 153A / 153C and not under section 148 of the Act did not require separate adjudication, when the reopening itself had been held to be invalid for wrong and irrelevant facts relied on by the Assessing Officer for reopening the completed assessment. Held that there was no failure on the part of the assessee to disclose the bank account during the original assessment proceedings or the post-search investigation. In the reasons recorded, the Assessing Officer has nowhere alleged that the bank account of the assessee was not disclosed during the original assessment proceedings. It is a trite law that the reasons recorded for the formation of belief of escapement of income chargeable to Income-tax have to be taken as they are and they cannot be improved upon subsequently. The Assessing Officer’s finding that the statement of H was recorded by the Department on March 29, 2012, but it was received by the Assessing Officer on February 4, 2019, could not be accepted because such information was available with the Department on September 15, 2014, the date of the passing of the original assessment order under section 143(3) of the Act, after verification of advance against sale of property from six persons. Therefore, the extended period of six years under the proviso to section 147 of the Act was not available to the Department. (AY.2012-13)