Since in the present case also notice has been issued after an expiry of four years from the end of the relevant assessment year, but before six years. This notice could be issued within limitation if the AO has made out a case that income exceeded rupees one lakh has escaped assessment. No such finding or observation or reference has been made in the reasons extracted (supra). In the opening line of the reasons, the AO has observed that as per information received from the ITO, Ward-16(1), Mumbai, the assessee carried out transaction in shares/securities with M/sGold Star Finvest. This information is factually incorrect or not cross-verified by the AO before recording reasons. The assessee has not carried out its share/security transaction with Gold Star Finvest in respect of which capital gain arose to the assessee stand ultimately considered by the AO for denial of exemption under s. 10(38) of the Act. Further, a perusal of the reasons would indicate that there is no coherence between the information available with the AOvis-a-vistransaction of the assessee, and formation of belief that income has escaped the assessment. These reasons are vague and inconclusive. Therefore, on the basis of such reasoning, the assessment cannot be reopened.