Where reopening for AY 2008-09 was based on cash sales which had already been added substantively in assessment for AY 2011-12 prior to issuance of notice under section 148, there could be no reason to believe that the same income had escaped assessment for AY 2008-09, particularly when the proceedings were not on a protective basis; accordingly, reopening notice for AY 2008-09 was quashed and, since the facts and issue for AY 2009-10 were identical, reopening for that year was also set aside. (AY. 2008-09 and 2009-10)