The assessment was reopened on the basis of information reflected in the Department’s portal that the assessee had received unsecured loans of ₹50 lakh under the category of “high-risk transactions”. The reasons recorded neither disclosed the names of the lenders nor the dates of the transactions, nor any tangible material indicating the escapement of income. The Tribunal held that the expression “reason to believe” requires specific and reliable material having a live nexus with the alleged escapement of income and cannot be substituted by a mere “reason to suspect”. Since the reopening was based only on vague and unspecified information without any supporting material, the assumption of jurisdiction under section 147 was without legal foundation, and the reassessment was quashed. (AY. 2013-14)