The AO sought to reopen assessments, some within and some beyond four years, based on information borrowed from the Directorate of Revenue Intelligence (DRI) and the Justice M.B. Shah Commission Report. The reasons cited were under-invoicing of exports and, for the older years, failure to disclose that mining activities were illegal. The High Court quashed the reopening notices, holding that the AO had not demonstrated any independent application of mind. Merely borrowing information and pasting it into the reasons recorded, without forming an independent belief that income had escaped assessment, is not permissible under Section 147. Furthermore, for the reopening beyond four years, the Court held that the assessee could not be faulted for failing to disclose the illegality of its mining operations. This illegality was only established by a Supreme Court ruling dated 21.04.2014, long after the relevant returns were filed. An assessee cannot be expected to disclose a fact that was not known or established at the time of filing the return. (AY. 2009-10 to 2011-12)