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of <h1>Reassessment notice upheld despite prior invalidation for 'borrowed satisfaction'; special leave dismissed after 142-day filing delay</h1> <h3>Asst. Commissioner Of Income Tax & Anr. Versus Godrej Agrovet Ltd.</h3> HC found the reassessment notice invalid for being issued on 'borrowed satisfaction' from a superior, concluding the AO did not apply his own mind. SC ... Reopening of assessment - eligibility of reason to believe - As held by HC [2024 (2) TMI 1588 - BOMBAY HIGH COURT] there is clear breach to the settled position in the law that reopening notice has to be issued by the AO on his own satisfaction and not on borrowed satisfaction. Admittedly, notice has been issued in view of a communication received from his superior officer. It is rather obvious that the AO has not applied his mind - Delayed filling SLP HELD THAT:- Though there is delay of 142 days in filing this Special Leave Petition, we nevertheless have heard learned counsel for the petitioners on the merits of the case also. We do not find any merit in the Special Leave Petition. Hence, the Special Leave Petition is dismissed. 'Though there is delay of 142 days in filing this Special Leave Petition, we nevertheless have heard learned counsel for the petitioners on the merits of the case also.' After consideration on merits, the Court held: 'We do not find any merit in the Special Leave Petition.' Accordingly, 'the Special Leave Petition is dismissed.' The application seeking condonation of delay is disposed of. All pending application(s), if any, stand disposed of. No substantive reasons beyond the brief observations on delay and merit are recorded.
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