Dismissing the petition the Court held that the statements of the witnesses were not the sole basis for passing the order but there were other documentary materials which had been considered while passing the order under section 148A(d). The Department based on the evidence in the form of documents, statements of entry operators and other key persons involved, facts and other circumstantial evidence and after recording satisfaction had issued notice under section 148 for initiating reassessment proceedings under section 147. There was no good ground to interfere with the order passed by the authorities under section 148A(d) and the consequent notice issued under section 148 for reopening the assessment under section 147.(AY. 2019-20)