Assessment was completed under section 143(3), read with section 147 allowing partial deduction under section 80IA  of the Act . On appeal CIT ( A) allowed the claim of the assesses. There was search on the assessee and block assessment order was  passed u/s 158BC of the Act and disallowed the claim u/s 80IA of the Act Thereafter, on 30-3-2004 the , Assessing Officer issued notice under section 148 alleging that assessee’s income chargeable to tax for assessment year 1997-98 had escaped assessment and calling upon assessee to file a return of its income within 30 days . On writ , allowing the petition the Court held that  on date on which impugned notice dated 30-3-2004 was issued, Assessing Officer could not have any reason to believe that income chargeable to tax had escaped assessment under section 148 because in block assessment order dated 30-1-2004, deduction claimed by assessee had been disallowed and therefore reopening of assessment on ground that deduction claimed by assessee under sections 80-I, 80-HHA and 80-IA had not been examined properly in regular assessment could not have been allowed . Reassessment notice was quashed . Followed  CIT v. H.N. Shindore  (1978 .) 113 ITR 679 ( Bom))( HC)  ( AY. 1997 -98 )