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The High Court held that the reasons recorded by the Assessing Officer for reopening the assessment u/s 147 were vague, based on borrowed satisfaction without application of mind, and lacked a nexus with the material available. The allegation of availing accommodation entries was not substantiated with prima facie evidence or opinion regarding escapement of income. The court found non-application of mind by the Assessing Officer, particularly regarding the alleged accommodation entry from Mahavir Sales Corporation, which the assessee had denied. Relying on precedents, the court reiterated that the Assessing Officer must confine to the recorded reasons for reopening and cannot refer to other facts or inferences. Consequently, the reopening of assessment was held invalid, and the decision was in favor of the assessee.
The High Court held that the reasons recorded by the Assessing Officer for reopening the assessment u/s 147 were vague, based on borrowed satisfaction without application of mind, and lacked a nexus with the material available. The allegation of availing accommodation entries was not substantiated with prima facie evidence or opinion regarding escapement of income. The court found non-application of mind by the Assessing Officer, particularly regarding the alleged accommodation entry from Mahavir Sales Corporation, which the assessee had denied. Relying on precedents, the court reiterated that the Assessing Officer must confine to the recorded reasons for reopening and cannot refer to other facts or inferences. Consequently, the reopening of assessment was held invalid, and the decision was in favor of the assessee.
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