Dismissing the petition the Court held that having regard to the materials on record it could not be said that there was total non-application of mind on the part of the AO while recording the reasons for reopening of the assessment. It also could not be said that his conclusion was merely based on the observations and information received from the Investigation Wing. The AO could be said to have applied his mind to them. The case on hand was not one where the AO on absolutely vague or unspecific information, initiated proceedings for reassessment without taking the pains to form his own belief in respect of such materials. In the overall view of the matter, no case was made out by the assessee for interference with the notice of reassessment. (AY. 2011-12)