The assessee had deposited donations received in cash in its bank account and thereby disclosed nil total income for relevant assessment year.  Accounts of assessee were recorded, accounted and audited. The AO issued notice for reassessment. On writ the Court held that there was no live link, which was a sine qua non between material before Assessing Officer in present case and belief which he had to form regarding escapement of income-Sanction under section 151 granted by prescribed authority as well as notice for reopening issued by Department was without any application of mind. High Court  held that, on facts, impugned reopening notice issued against assessee was unjustified and same was to be set aside.  Revenue filed SLP. Court  held that  there being gross delay of 246 days in filing SLP by revenue, which had not been satisfactorily explained, SLP dismissed. (AY. 2014-15)