The High Court quashed the reassessment proceedings initiated under section 147 by holding that the AO’s reliance on borrowed satisfaction from third-party search information without independent application of mind or furnishing underlying material was invalid. Further, the underlying material, seized documents and statements were not supplied to assessee on the plea of confidentiality. Also, objections were rejected without disclosure of incriminating material or establishing a nexus with alleged escapement, thereby vitiating the statutory condition of ‘reason to believe’. In the absence of tangible material and a rational link, the reopening proceedings were held to be without jurisdiction. SLP of revenue was dismissed.  (AY. 2013-14 to 2015-16)