Dismissing the petition the Court held that  having regard to the materials on record it could not be said that there was total non-application of mind on the part of the Assessing Officer while recording the reasons for reopening of the assessment. It also could not be said that his conclusion was merely based on the observations and information received from the Investigation Wing. The Assessing Officer could be said to have applied his mind to the same. Hence the notice for reassessment was valid.(AY.2012-13)