There being no whisper in the reasons recorded by the AO that the assessee has applied its income for any particular religion or caste in violation of s. 13(1)(a), the information received from the Dy. CIT(E) that a large amount of foreign contributions has been received by the assessee-trust for carrying out religious activities, in the absence of any independent enquiry by the AO or any relevant tangible material, cannot be a reason to believe that assessee’s income has escaped assessment and therefore, the reopening of assessment and the consequential reassessment are bad in law. (AY.2010-11 & 2011-12)