Allowing the petition the Court held that though there was a reference to information relied on for formation of the belief that income had escaped assessment under section 147 by the Department, the documents and material information requested by the assessee were not made available to him. In the absence of such materials and necessary information the assessee would not be in a position to justify his acts and conduct, nor would he be able to provide a reasonable explanation with regard to the information collected and relied on by the Department. Therefore, the order under section 148A(d) and the notice issued under section 148 is   quashed and set aside. Matter remanded.