Section 147 of the income tax Act, 1961 — Reassessment — While it is true that the Court is conscious that the reassessment notice should not have been routinely issued, at the same time, the nature of power is wide enough that when there is an escapement of income and the revenue had information that this escapement is also relatable to the suppression of material facts, the power to reopen concluded assessment can validly be exercised. Having regard to the material on record, it cannot be said that there is a total non-application of mind on the part of the AO while recording the reasons for reopening of the assessment; it also cannot be said that his conclusion was merely based on the observations and information received from the Investigation Wing. AO could be said to have applied his mind to the same; writ petition was not therefore sustainable—Hemjay Construction Co P. Ltd. vs. Income Tax Officer [2019] 311 CTR (Gujarat) 413