Tribunal held that notice under section 148 was issued merely on the basis of the information from the Director of Income-tax that the assessee had received accommodation entry . There was no mention of any application of mind or any independent inquiry or any link between any tangible material and formation of reasons to believe that income chargeable to tax has escaped assessment. In the reasons recorded, the Assessing Officer had made vague remarks that the assessee had income chargeable to tax which had escaped assessment. The Assessing Officer had not even specified what was the amount of alleged income escaping assessment, which showed that the Assessing Officer had merely recorded certain unsubstantiated allegations on the basis of some information received. Therefore the proceedings initiated by invoking the provisions of section 147 were non est in law and without jurisdiction.( AY.2008-09)