Allowing the petition the Court held that it is well-settled position of law that reason to belief that the income has escaped assessment has to be on the sole reasonable belief of the AO himself and cannot be an opinion and/or belief of some other authority. It is expected of the AO that though the information/material is received from other sources, the AO is required to consider the material on record in case of assessee by applying his independent mind and upon appreciation of such information/material on record, the AO is further expected to form his independent opinion to arrive at satisfaction which constitutes “reason to believe” that income of the assessee, which otherwise was chargeable to tax has escaped the assessment for any assessment year. Entire base for reopening assessment is on the premise that there was ‘Information’ supplied by the Investigation Wing and the AO has made cursorily reference to high value transaction of Rs. 26,42,027 as well as also referred to accommodation entry entered upon by the assessee-company by way of bogus sales/purchases/fictitious loans etc. Thus, reasons for reopening of the assessment in the case of assessee-company by the AO is based on the borrowed satisfaction and the AO has not applied his independent mind to arrive at the conclusion that there was failure on the part of the assessee to disclose fully and truly all material facts. Reopening was not therefore sustainable. Accordingly the notice and order disposing the objection is quashed. (AY. 2014-15, 2015-16)