The petitioner challenged the notice issued u/s 148 of the Act , on the ground that there was not even a whisper as to what was the tangible material in the hands of the AO which made him to believe that income chargeable to tax has escaped the assessment and what was the material fact that was not fully and truly disclosed . Allowing the petition the Court held that in the reasons for reopening the AO  does not even disclose when the search  and survey action 132 was carried out . The reasons  for reopening are absolutely silent as to how the search and survey action on M/s Evergreen Enterprises or the statement referred to or relied upon in the reasons have any connection with the petitioner . The reassessment notice was quashed and set aside .  (AY. 2012 -13)