Allowing the petition the Court held that the reasons recorded by the assessing authority for assuming was unfounded, non-existent. The assessing authority had formed the reasons to believe on the ground that the assessee had sold an immovable property and earned capital gain during the financial year 2012-13 relevant to the assessment year 2013-14 but it was not shown in his return of income. The assessing authority could not have assumed jurisdiction to issue the notice under section 148, therefore, the notice itself was without jurisdiction and unsustainable. Consequently, the reassessment order passed was quashed. (AY.2013-14)