Held, dismissing the writ petition, that the decision to reopen was based on tangible information, which was not in the possession of the officer at the time of carrying out the assessment proceedings. The information was revealed during the survey proceedings under section 133A of the Income-tax Act, 1961 and therefore the reopening under section 148 would be the proper course of action since proceedings under section 153C would be the result of search proceedings under section 132A and not survey proceedings under section 133A. Furthermore, the reliance placed on Instruction No. 1 of 2011  [F.No. 187/ 12/2010-IT (A)n-1)) dated January 31, 2011 was also misplaced since that was with respect to assessment proceedings and not proceedings initiated pursuant to section 148 of the Act. Reading such instructions to override the effect of section 148 read with section 151 of the Act would be contrary to the intent. The notice of assessment was valid. (AY. 2011-12)