Section 147 & 148 of the Income Tax Act, 1961— Reassessment— The reason to believe has been incorporated for the subjective satisfaction of the AO and not for the purpose of communicating all the reasons even at the initial stage of issuance of notice to the assessee under section 148; the provision is a check for IT Officials and such a check provided under the statute to the officials cannot be taken undue advantage by the assessee. The issuance of notice as an information provided to the assessee enabling him to avail of all further opportunities contemplated under the statutes, thus, the court cannot come to the conclusion that non quoting of the reasons by the AO in the impugned notice will vitiate the entire proceeding and if such a proposition is adopted, then it would be certainly difficult for the executives to reopen the cases as per the provisions of the Act — Dayanidhi Maran vs. Assistant Commissioner of Income tax v [2018] 305 CTR (Madras) 233