Where the Assessing Officer reopened assessment pursuant to directions of the Additional Commissioner and Joint Commissioner following a transfer pricing adjustment suggested by TPO, and the Tribunal found that the Assessing Officer had not independently applied his mind to material on record, since under section 147 it is the Assessing Officer alone who must form the belief that income has escaped assessment and such belief cannot be substituted by satisfaction of any other officer, reassessment proceedings initiated by the Assessing Officer acting under dictation of his superiors were rightly quashed.  (AY. 2008-09)