Assessee-firm is engaged in export of Iron Ore. It had filed its return of income declaring loss which was processed under section 143(1). Later, assessee was served with reassessment notice on basis of Report of Justice Shah Commission on ground that invoices issued by assessee were below international price. On writ the Court held that  report relied by revenue was wholly subjective and no other fact was gone into or brought out in Report to suggest that invoice price was deliberately suppressed or that actual consideration received was more. Since there was no material in that regard, reassessment proceedings being initiated without any tangible/ relevant material to form any reason to believe as to escapement, reassessment proceeding is quashed.  (AY. 2011-12)