The Hon’ble High Court noted that the Reassessment notice was founded on a bogus ‘sauda chitthi’ produced by the complainant, which was neither stamped, registered, nor notarized and was merely on plain paper. Further, it was found that no sale deed was executed and the properties continued to stand in the assessee’s name and possession was never handed over. The High Court held that there was no transfer of a capital asset under section 2(47) and hence no income accrued either by way of sale deed or handing over possession; therefore, there was no escapement of income due to failure to disclose material facts. Reopening beyond four years was invalid and notices under section 148 were quashed. SLP of revenue was dismissed on account of delay of 846 days as well as on merits. (AY. 2014-15)