Dismissing the petition the Court held that mere failure to quote the provision of law would not vitiate the entire reassessment proceedings, though the competent authorities are expected to quote the provisions of law.   That certain facts placed by the assessee before the court could not be wholly relied upon. The Department without conducting an enquiry and scrutinizing the documents, would not be in a position to place all the facts before the court. Therefore, the scope of interference in initiation of reassessment proceedings would be limited and, the court in such circumstances should refrain from preventing the competent authorities from conducting further enquiry by following the procedures as contemplated on initiation of proceedings under section 147. Reassessment notice is held to be valid. (AY.2007-08)