Allowing the petition the Court held that the initiation of reopening proceedings were on borrowed satisfaction since no independent opinion was formed. Therefore, without forming such opinion, solely and mechanically relying upon the information received from the other sources, the Assessing Officer could not have assumed the jurisdiction to reopen the assessment. Accordingly, the notice issued under section 148 for the assessment years 2014-2015 and 2016-2017 and the order rejecting the assessee’s objections were set aside.(AY. 2014-15, 2016-17)