Tribunal held that the Assessing Officer had merely gone by the Central Investigation Bureau report and was not even in possession of the sale deed and the exact specifics of the transaction at the time of recording of reasons. The registered sale deed was obtained by the Assessing Officer after recording the reasons. There was no tangible material in the hands of the Assessing Officer to have any reason to believe that income had escaped the assessment. The reasons recorded or the documents available on record, did not show a link or nexus and relevancy to the opinion formed by the Assessing Officer regarding escapement of income. Further, even though the reopening was after the expiry of four years from the end of the assessment year 2008-09, given that there was no return of income filed by the assessee and consequent assessment, it was not necessary for the Assessing Officer to show that there was any failure to disclose fully or truly all material facts necessary for the assessment in terms of proviso to section 147 of the Act. (AY.2008-09)