The Hon’ble High Court held that there is no ‘close nexus’ or ‘live link’ between tangible material and the reason to believe that income has escaped assessment. The information received from the Investigation Wing cannot be the sole basis for forming a belief that income has escaped assessment. Having received information from the Investigation Wing, it was incumbent upon the Assessing Officer to take further steps, make further enquiries and garner further material and if such material indicate that the income of the assessee has escaped assessment and then form a belief that the income of the assessee has escaped assessment. As the AO has not acquired any such material to form the reason to believe that any income has escaped assessment, impugned notice issued under section 148 of the Act is bad in law.(AY. 2011-12)