`

An information was received from DDIT (Investigation) that certain material/document was recovered which showed that assessee had entered into certain financial transactions and made some potential cash borrowings from several parties. The  Assessing Officer issued  notice for  reopening of the assessment.  On writ High Court held that  report was as vague as possible as it stated that possible financial transactions could be deduced and decoded from hard copies obtained from DDIT and there was “potential” cash borrowed from various lenders and “probable” names of group were mentioned and set out without any particulars and that said material was not made available to assessee so as to enable it to give an effective reply and that Assessing Officer did not independently apply its mind to information furnished by DDIT which he was required to do while exercising power to reopen assessment. High Court, on facts, held that  notice for reopening of assessment was bad in law and  set aside. SLP of the Revenue  is dismissed as the  explanation given for condonation of delay of 399 days in filing SLP against order of High Court was not sufficient in law to condone delay.