Where reassessment proceedings are initiated solely on the basis of third-party information obtained during a search, without any tangible material linking the assessee to the alleged escapement of income, and where the AO records reasons mechanically without independent application of mind, the assumption of jurisdiction under sections 147/148 is invalid. Non-supply of the underlying material to the assessee on the ground of departmental confidentiality cannot cure the defect. In the absence of a live nexus between the information received and the belief that income has escaped assessment, the reopening notice is liable to be quashed. The Supreme Court dismissed the Revenue’s SLP, thereby affirming the High Court’s view. (AY. 2013-14 to 2015-16)