Assessee-firm, engaged in the business of trading in rough diamonds as well as cut and polished diamonds, filed its income tax return. Pursuant to information received from the portal, the Assessing Officer issued a reopening notice against assessee on the ground that two, Shree Vasudev Babubhai Kapadia and Janak Vaudev Kapadia  had carried out huge transactions in the form of bogus purchases and sales from assessee through an undisclosed bank account, thus  it was concluded that income had escaped assessment. On writ, it was argued that the assessee had maintained regular books of account and got them audited every year within time and uploaded them on the IT portal. Further, all transactions of the assessee, including those with one, Vasudev Babubhai Kapadia, were duly reflected in the profit and loss account. The assessee had dealt with information supplied to it by the revenue and had meticulously satisfied the data by comparing it with the books of account. Upon such comparison, it had categorically replied that, so far as a certain amount was concerned, the same did not figure in the books of account, whereas a certain amount pertained to sales of rough diamonds to one, VE, proprietor Janak Vaudev Kapadia  for which all details were offered. However, the Assessing Officer had cursorily and perfunctorily responded that the same would be looked into during assessment proceedings. Further, the entire allegations of bogus purchases were confined to Shree Vasudev Babubhai Kapadia. Assessee, in its reply and in filing assessment and ITR, had clarified transactions with Shree Vasudev Babubhai Kapadia. Court held that since there was nothing recorded in the order which would satisfy that the Assessing Officer had reason to believe that the assessee’s income chargeable to tax had escaped assessment, proceedings under section 148 were uncalled for.  Accordingly, the reassessment notice and consequential orders were quashed.  (AY.  2019-20)