Held that the Assessing Officer did not have any material over and above the material already with the Department to justify the reassessment proceedings under section 147 in the light of the new scheme for the assessment years 2014-15 and 2017-18 after a period of seven years. The contention of the Department was only that the methodology followed at the time of the original assessment under section 143(3) ought to have been different. The Assessing Officer had merely referred to the financials, form 3CD, profit and loss account, computation statement and the details furnished during original assessment. There was no new or tangible information or material to justify reassessment since all relevant information was available with the original authority. There was no averment in the notice issued under section 148 that “information” had been received indicating escapement of income attributable to the assessee. There was no allegation that any new material had been found which was to be examined. The Assessing Officer had himself stated in the reasons recorded that all materials in relation to foreign currency borrowings and transfer of assets to asset reconstruction companies had been fully and comprehensively placed at the time of the original proceedings. The original assessment order had specifically recorded detailed examination of the financials of the assessee. The Assessing Officer had examined all aspects of the return of income and had made an assessment after thorough scrutiny. The reassessment proceedings were initiated based on the financial records already available with the Assessing Officer and indicating that a different view invoking section 43A in respect of unrealised loss should have been taken. As regards the sale consideration from assets transferred to asset reconstruction companies, the Assessing Officer had recorded that income had been offered under the head “Other sources” but had expressed the view that the sale consideration ought to have been offered in full and not amortised over the years.The reference to “information” in the Explanation to section 148 relates to information flagged in the risk management strategy formulated by the Central Board of Direct Taxes or a final objection raised by the Comptroller and Auditor General pointing to a flaw in the assessment made earlier. No risk management strategy had been placed before the court despite a specific query in this regard. Only some specific information that had come to the knowledge of the Assessing Officer, and hitherto unknown, would satisfy this requirement. Such information must be tangible and new and stale information already part of the record would not qualify. The term “flagged” has been omitted from this clause with effect from April 1, 2022 by the Finance Act 2022. Therefore, the material already on record and that had undergone scrutiny at the first instance could not satisfy the statutory condition. Hence the assumption of jurisdiction for initiation of proceedings for reassessments by the Assessing Officer was bad in law and, therefore, quashed. The books of account and material were furnished by the assessee at the time of original assessment and there was no mention anywhere in the reassessment proceedings about an “asset” which represented income that was alleged to have escaped assessment. The notices and proceedings for reassessment were quashed.(AY.2014-15, 2017-18)