Assessing Officer issued reopening notice on ground that petitioner entered into a transaction amounting to Rs. 45 lakhs.  Petitioner filed its objection by submitting documentary evidences which showed that no transaction amounting to Rs. 45 lakhs was entered by petitioner during year under consideration. The order was passed disposing the objection. On writ allowing the petition the Court held that Revenue submitted counter affidavit where no response was provided for query raised with respect to reason to believe for issuance of reopening notice. Furthermore, reassessment order specifically mentioned that on perusal of documentary evidence submitted by petitioner no inference could be drawn in connection with amount of Rs. 45 lakhs.   Since reasons to believe recorded by Assessing Officer were totally unfounded, reopening notice was without jurisdiction and  reassessment order was quashed. High Court also imposed cost of Rs.5000 on Revenue.