The assessee did not file its return of income for the relevant assessment year. The Assessing Officer, based on information that the assessee had received certain amounts, issued a notice under section 148 on 27.03.2021. The assessee failed to file a return in response within the stipulated time and did so only after eight months, when the time limit for completing the reassessment was about to expire. The High Court dismissed the assessee’s challenge, holding that the Assessing Officer had a valid reason to believe that income had escaped assessment. The Court observed that since the assessee had not filed any return, had not responded to the notice in time, and had not explained the receipt of the amount, the reopening was justified. It was also noted that Explanation (2) to section 147, which deems income to have escaped assessment where no return is filed despite income exceeding the maximum non-taxable amount, was applicable. The Court clarified that the assessee’s arguments on the merits could be presented during the reassessment proceedings. (AY. 2015-16)