The Assessing Officer reopened the assessee’s assessment based on information from another AO that the assessee had received a cash deposit and then transferred it by cheque to a company. The High Court quashed the notice under Section 148, holding that the reopening was invalid. It was ruled that an AO must form an independent “reason to believe” and cannot act mechanically on borrowed satisfaction from another officer. A reopening cannot be based on a mere “reason to suspect” or be used to conduct a roving inquiry. Furthermore, the Court noted that since the same income had already been assessed in the hands of the company for the same assessment year, it could not be simultaneously taxed in the hands of the assessee. (AY. 2007-08)