Assessee filed its return of income showing agricultural income of certain amount which was accepted.  On the basis of an advisory issued by department the AO was directed to thoroughly verify claims in respect of agricultural income earned by several parties including assessee.  On basis of same, AO issued notice u/s.148 against assessee so as to treat its agricultural income as income from undisclosed sources.  On writ the revenue admitted that the advisory contained in a letter which was issued in light of an order passed by this Court on a public interest litigation and required verification of agricultural income for certain period, which also included assessment year in question.  Advisory directed AO to verify whether there was any data entry error in returns filed; to provide feedback where assessment was complete and in cases where assessment was pending, to thoroughly verify claims on agricultural income. Allowing the petition the Court held that reopening was simply founded on advisory issued by department and there was no tangible material in possession of AO for formation of belief about escarpment of income chargeable to tax, therefore reopening notice was unjustified. (AY. 2011-12)