A search was conducted upon assessee during which certain documents were found and seized which showed that assessee had made substantial amount of unexplained investment in purchase as well as on construction/renovation of immovable properties, which had not been shown by assessee in his accounts/ITR. Accordingly, on basis of DVO’s report he arrived at satisfaction that aggregate of income of assessee which had escaped for relevant assessment years was more than Rs. 50 lakhs, hence he reassessed income of assessee under section 153A.  However, there was no difference found between investment disclosed by assessee in books of account as compared to DVO’s report.  Further, DVO’s report on standalone basis without any corroborating material cannot be construed as incriminating material. Tribunal held that since evidence relating to undisclosed investments in respect of relevant assessment years as defined in Explanation 1 to 4th Proviso of section 153A(1) was less than Rs. 50 lakhs, reopening of assessment of relevant years being beyond six years is  bad in law and hence  quashed. (AY. 2009-10, 2011-12)