The assessee challenged the notice under section 148 and order disposing the objection under section.148A(d) of the Act. Dismissing the petition the Court held that there is no dispute that the information has been found recorded in the electronic books of accounts of a third party OMX Ltd.  There is also no doubt that the said entries have been found recorded against the name of the assessee as the  depositor. Assessee has not denied (either before the assessing authority or this Court) his ownership or rights or interest in the two properties. On an analysis done by the Revenue authorities, they have formed an opinion that the entries found recorded in the electronic books of accounts of OMX Ltd. are coded. Both with respect to date and quantum, there are deliberate alterations made to hide the true identity of the transactions. Prima facie, the quantum of escapement noted by Revenue authorities exceeds Rs. 8 crores.  Therefore, the period of limitation would be governed by S. 149(1)(b).  Further, the Writ Court may not remain over sensitive to the technical concern being voiced. Once opportunity has been actually and substantially availed on a realistic time scale, the Court is not inclined to set aside the order under s. 148A(d) dt. 6th March, 2024 passed by the assessing authority. The legislature has consciously widened the scope of assumption of jurisdiction to reassess any assessee. In the minimum, the objective test that was required to be satisfied under the pre-existing law by recording appropriate “reason to believe” has been done away. (AY. 2017-18)