Allowing the petition the Court held that it was only after examination of the sale transaction of the land and related issues, that the Assessing Officer had passed the order under S. 143(3) Along with the sale deed, the assessee had also filed a report of the valuer who had estimated the cost of construction of staff room, office, godown, labourers’ rooms, compound wall, borewell, etc., at Rs. 5.09 lakhs. The reasons recorded lacked validity and there was lack of application of mind on the part of the Assessing Officer when he had conveyed that the cost of improvement of Rs. 5.09 lakhs was not reflected in the assessee’s books of account. The notice issued under S. 148 for reopening the assessment was quashed.( AY.2012-13)