Sec. 147 & 148 of Income Tax Act, 1961—Reassessment—Initiation of the proceedings under Section 147/148 to reopen the assessments for the AYs in question does not satisfy the requirement of law as the reasons to believe contain not the reasons but the conclusions of the AO one after the other and there is no independent application of mind by the AO to the tangible material which forms the basis of the reasons to believe that income has escaped assessment and the conclusions of the AO are at best a reproduction of the conclusion in the investigation report and indeed it is a ‘borrowed satisfaction and the reasons fail to demonstrate the link between the tangible material and the formation of the reason to believe that income has escaped assessment — NIGAM COMPUTERS PVT. LTD. Vs. ITO  [2020] 78 ITR (TRIB) 384 (ITAT-DELHI)