The assessee challenged a notice issued under section 148 seeking to reopen its assessment. The reasons recorded for reopening indicated that the Assessing Officer (AO) had acted merely on the dictates of a revenue audit objection. Quashing the notice, the High Court held that the ‘reason to believe’ that income has escaped assessment must be the AO’s own and cannot be based on borrowed information. While an audit party may bring relevant aspects to the AO’s attention, the decision to reopen the assessment must stem from the AO’s independent application of mind and formation of belief. Since the reopening was initiated at the behest of the audit party without such independent belief, the notice was not sustainable. Circular No. 14/19/56-II, dated 28-7-1960.  (AY. 2012-13)