Dismissing the petition the Court held  that the Department had received information that the value of land, which was subject matter of transaction of sale, was far more than what had been disclosed. Therefore, on the face of it, it was a case where the Department had collected certain information regarding certain income having escaped assessment. Whether or not the information was reliable, would be required to be examined at subsequent stages and at this stage, the court would not go into the disputed questions of fact. The assessee had not alleged procedural impropriety, irregularity or violation of statutory provisions in the matter of initiation of proceedings or passing of the order under section 148A(d) . The order and consequential notice of reassessment were valid.