Assessee, along with co-purchasers, purchased land through a registered sale deed. Subsequently, a search was conducted at a broker’s premises, where inquiry registers containing details of lands, survey numbers, areas and asking rates were seized  Assessing Officer relied upon a noting in the seized inquiry register relating to certain survey numbers and alleged that assessee had paid on-money of Rs. 3.74 crores over and above the sale consideration recorded in the registered deed. Accordingly, the Assessing Officer issued notice under section 148 alleging escapement of income on account of undisclosed investment in land purchase. On writ, the Court held that the noting in the inquiry register predated the actual purchase transaction of the assessee by a considerable period. Further, the register entry pertained to five survey numbers; however, the assessee had purchased only two survey numbers. Thus, the register entry covered three additional survey numbers and referred to more than double the area of land actually purchased by assessee. Further, the name appearing in the seized inquiry register was of a person who was entirely unconnected to and unknown to the assessee. Since the seized inquiry register entry did not establish any live nexus with the assessee, the reopening notice issued against the assessee was quashed and set aside.    (AY. 2021-22)