Independent satisfaction in reassessment prevents Board directions from replacing a reasoned belief that income escaped assessment.

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....Independent satisfaction of the Assessing Officer is required before reassessment can be initiated; a Board instruction cannot substitute for a reasoned belief that income escaped assessment. Where interest income was disclosed in a return, even if the return was treated as invalid, and no material shows that related expenses were wrongly claimed or disallowable, the available material may justify examination of net profit only. It does not support treating the entire interest income as escaped. Reassessment reasons reflecting only perfunctory compliance with directions therefore lack the required basis, rendering the notice and consequential assessment invalid.....