Notices were issued under section 148 of against the assessee for reopening the assessments. The reasons recorded stated that the notices were issued on the ground that the assessee’s transactions for the financial years 2015-16 and 2016-17 were flagged in the Non-Filers Monitoring System (NMS) and that according to form 15CA, the assessee had made a remittance to its head office without deducting tax thereon claiming the payment to be tax-free under the Double Taxation Avoidance Agreement between India and the U. S. A. The objections raised by the assessee were rejected. On a writ petition the Court held that the issue of dividend income and long-term capital gains on the sale of shares required a detailed consideration. The notices under section 148 had been issued within four years from the end of the relevant AYs and there had been no scrutiny assessments. Consequently, the test to be applied for reassessment, whether there was “reason to believe” that income chargeable to tax had escaped assessment, was satisfied. However, the contentions and submissions raised by the assessee were relevant and must be examined by the Assessing Officer while passing the reassessment order. The assessee could establish in the reassessment proceedings under section 147 that the assumption of facts made in the notices were erroneous. (AY. 2016-17, 2017-18)