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Reopening of assessment was invalid as the Assessing Officer (AO) recorded reasons without independent application of mind or verification of facts. The AO merely repeated information received from the investigation wing regarding alleged unexplained credits u/s 68, without examining bank statements or other evidence. The AO's conviction about receipt of accommodation entries was unsupported by corroborative evidence. The reasons were recorded under borrowed satisfaction, without the AO possessing or analyzing the relevant information. Consequently, the reopening proceedings u/s 147 by issuing notice u/s 148 were invalid due to lack of proper reasons and failure to apply mind to the material facts.
Reopening of assessment was invalid as the Assessing Officer (AO) recorded reasons without independent application of mind or verification of facts. The AO merely repeated information received from the investigation wing regarding alleged unexplained credits u/s 68, without examining bank statements or other evidence. The AO's conviction about receipt of accommodation entries was unsupported by corroborative evidence. The reasons were recorded under borrowed satisfaction, without the AO possessing or analyzing the relevant information. Consequently, the reopening proceedings u/s 147 by issuing notice u/s 148 were invalid due to lack of proper reasons and failure to apply mind to the material facts.
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