The assessee filed writ against the reassessment proceedings.  Allowing the petition the Court held that reopening of assessment could be made only when Assessing Officer has a reason which is present in his mind when he forms his reason to believe that income has escaped assessment; statute does not contemplate reopening of an assessment under section 148 on a hypothesis or a contingency which may emerge in future. Where though assessment had already been made in hands of association of persons, Assessing Officer sought to reopen assessment to make protective addition in hands of assessees, proceedings under section 148 were wholly without jurisdiction. (AY.  2019-20)