Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Reopening of assessment - non-application of mind by AO - Borrowed satisfaction - Reliance on investigation initiated by Directorate General of Goods and Services Tax (“DG GST”) - The court observed that both the AO and the PCIT failed to properly assess the information and circumstances before approving the reopening notice. They did not adequately verify the petitioner's compliance with disclosure requirements or consider the timing constraints for issuing such notices. This lack of diligence amounted to a total non-application of mind, rendering the approval and subsequent proceedings unsustainable.
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