In the reasons provided it is stated that the assessee has transferred shares during year under consideration whose market value on the date of transfer was Rs. 7.63 crores (rounded off). This transfer had taken place in favour of sister concern without consideration under transfer deed dated 26.02.2010. In view of such facts, the Assessing Officer has reason to believe that the income chargeable to tax in excess of Rs.1,00,000/- had escaped assessment. Held that reasons themselves record merely the transaction and nothing more. There is no live link between the first portion of the reasons recorded, namely, by merely duplicating the recording of transaction of transfer of sizable number of shares having considerable market value without consideration and second portion of the reasons where he concluded that the income chargeable to tax had escaped assessment. Hence reopening u/s 148 can not be made. [Para 9 and 10 of the Judgement] Comments: This judgement can be helpful where cases are reopened u/s 148 merely on the basis of AIR information Prakriya Pharmacem [2016] 66 taxmann.com 149 (Gujarat) JANUARY 18, 2016