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The HC held that the AO did not independently verify the material on record or form an opinion that income escaped assessment due to the assessee's failure to disclose facts. The reopening was based on borrowed satisfaction from information received without independent application of mind. Merely relying on information from other sources without forming an independent opinion is impermissible for reassessment proceedings. The HC decided in favour of the assessee.
The HC held that the AO did not independently verify the material on record or form an opinion that income escaped assessment due to the assessee's failure to disclose facts. The reopening was based on borrowed satisfaction from information received without independent application of mind. Merely relying on information from other sources without forming an independent opinion is impermissible for reassessment proceedings. The HC decided in favour of the assessee.
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