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of The High Court revisited the reopening of assessment u/s 147 due to the assessee's involvement in penny share transactions. The petitioner invested in shares through IPO and provided necessary details during regular assessment. The Assessing Officer relied on information from DDIT Investigation Unit to allege income escapement. However, the Court found that the AO lacked independent application of mind, as the reasons recorded did not establish a direct connection between the information and the transactions. Consequently, the jurisdiction was deemed based on borrowed satisfaction, leading to a decision in favor of the assessee.
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