There is complete non-application of mind as the Assessing officer didn’t convert the information per se into tangible material. He just relied on the general information and he didn’t make any inquiry or apply his mind to the information received. The assessing officer should form nexus between information, reason, and belief. This is absent in this case. The Assessing Officer rejected the claim of assessee u/s 10(38) and made addition u/s 68 for consideration received by the assessee on sale of shares and both these sections were not even referred in the reasons recorded. The statement cannot form the basis for reasons recorded being a statement in the dark as it was never supplied or referred in the show cause notice issued or reproduced in the assessment order. Assessing Officer has taken the action u/s 147 for verification or making fishing inquiry which cannot be permitted.