The petitioner is in the business of Iron ore mining services, transportation and handling of iron ore limestone etc. The assessment was completed u/s. 143 (3) of the Act. The petitioner filed an application u/s 154 stating that TDS amount was not taken in to account and interest was levied under section 234B of the Act. The Assessing Officer issued notice u/s 148 of the Act `on the ground that there was huge difference between the data reflected in Form No 26AS and the statement was up dated from time to time. The Assessing Officer has also relied on the Shah Commission report as regards illegal activities of mining. The objection for recording of reasons was rejected by the Assessing Officer. On Writ the asseasee contended that the reassessment notice was beyond four years and there was no failure to disclose any material facts. Dismissing the petition the Court held that the AO had culled out certain factors based on the rectification application filed by the assessee under section. 154 of the Act. The AO had sufficiency reason to believe. The sufficiency of reason cannot be gone in to by the High Court in a writ proceedings. Against the judgement of the Single judge an appeal was filed. Dismissing the petition the Court held that the issue which is now subject matter of the reopening of assessment was never discussed during the original assessment proceedings and no opinion was formed by the Assessing Officer during the original assessment proceedings. The reassessment proceedings are valid. (AY. 2008-09 to 2010-11)