Allowing the petition the Court held that there should have been a live link between the information that was surfaced for issuance of notice under section 148 to reopen the assessment and to pass fresh reassessment order under section 147. It could not be said that the Assessing Officer was unaware of the search proceedings and the seizure made pursuant to the search conducted on September 3, 2013 resulting in seizure of cash from the assessee and its partner and gold recovered from related party. The notice issued under section 148 inspired by change of opinion and the order rejecting the assessee’s objections were quashed and set aside.