Allowing the Writ of the assessee, Delhi High Court noted that reopening was initiated on the basis of ‘reasons to believe’ which contained information about letter from ITO(Nahan) and an FIR and Charge sheet including names of Director. of the belief that income, otherwise chargeable to tax, had escaped assessment. As per Reasons to believe, AO initiated reopening by stating that there is increase in funds from previous year and had no tangible material and no evidence against the assessee. Merely a case of suspicion. Sine qua non for triggering the assessment proceedings is not a ‘reason to suspect’ but a ‘reason to believe’ that income chargeable to tax has escaped assessment. AO was also unaware about the nature of deposits which is evident from the following observations made by him: “…may be in the guise of Share Capital, including Share Premium, bogus sales to Ms Para Impex Chem, or Long term loans or all…”. Mere increase in source of funds, without any corroborative evidence, cannot be basis of the belief that income, otherwise chargeable to tax, had escaped assessment. Notice u/s. 148 quashed. As regards argument of petitioner that AO did not supply copy of FIR and Charge sheet filed by CBI, to the petitioner, High Court noted that we do not lay much store on this assertion, as names of Director were mentioned in FIR and this information would have already been available with the petitioner in the ordinary course. (AY.2011-12)