Dismissing the petition the Court held that  there was reason to believe that the income chargeable to tax had escaped assessment. The reopening of the assessment under section 147 had been made only after due inquiries and recording of statements of concerned persons and on having found prima facie material, the notice under section 148 was issued to the assessee. The Assessing Officer had reason to believe that the assessee was a beneficiary of accommodation entry and the basis for formation of such belief was several inquiries and the investigation by the Investigation Wing and report thereof. The reasons for the formation of the belief by the Assessing Officer had a rational connection with or relevant bearing on the formation of belief that there had been escapement of the income of the assessee from assessment in the particular year because of his failure to disclose fully and truly all material facts. Writ petition was dismissed.  (AY. 2013-14)