AO issued  a notice under S. 148 of the Act based on information received from DGIT (Inv.) pertaining to a search case of entry operator bringing to tax in the assessee’s hands undisclosed income by way of accommodation entry. The tribunal held that the reasons to believe neither show any reasons recorded by independent application of mind by AO nor any nexus between tangible material and formation of belief that income had escaped assessment. Conclusion of the AO on the basis of information received by him constituted a borrowed satisfaction and the reasons for initiating reassessment proceedings are against the spirit of the provisions of  S. 147 and notice issued under S.  148 of the Acton suggestions of DGIT(Inv.) by AO is bad in law. (AY.2010-11)