Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
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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