Dismissing the petition the Court held that the High Court is not an expert body, so as to go into the details of the accounting system and find out arithmetic errors, if any. What is to be considered in a writ petition mainly with reference to the cases of reopening of assessment is the “reasons to believe” for reopening of assessment. The reasons furnished should have live link with the materials and the conditions stipulated are to be complied with. If these aspects are satisfied, such an objective satisfaction would be sufficient for the purpose of allowing the assessing authority to proceed with the reassessment proceedings and conclude them by providing opportunity to the assessee. The sufficiency of the reasons need not be gone into by the High Court in writ proceedings. Thus, if there is a prima facie case for the purpose of reopening of assessment, objective satisfaction is sufficient for the purpose of reopening of assessment. Since the Assessing Officer had not applied his mind and formed any opinion on the issues for which the case had been reopened, it could not be argued that reassessment was based on change of opinion or that the issues for which the case was reopened had already been disclosed by the assessee and dealt with by the Assessing Officer in the original assessment. The reassessment proceedings must go on. The assessee had to avail of the opportunity to be provided to defend its case with regard to the allegations of under assessment or excessive relief or otherwise and co-operate for the early completion of the reassessment proceedings. (AY. 2009-10)