During relevant assessment year, the  assessee-company raised capital by issuing  optionally Convertible Preference Shares with face value of Re. 1 at a premium of Rs. 999 to company  which was its sister concern.  Assessment was made under section 143(1).  Assessing Officer reopened assessment on ground that based upon analysis of details and information of balance sheet, share premium charged was not justified on basis of ‘intrinsic valuation of shares and Net Asset Value Method and to that extent income had escaped assessment Since  the Assessing Officer had not doubted  regarding transaction having taken place between said two companies with regard to allotment of preference shares and receipt of share premium amount and assessment in case of company  had become final, there was neither any basis for Assessing Officer for his reason to believe that income had escaped assessment nor was there any tangible material which would have otherwise given jurisdiction to reopen assessment even when reopening was sought to be made within a period of four years.Reassessment notice is  quashed. (AY. 2010-11, 2011-12)