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The ITAT quashed the reopening of assessment under section 147, finding it invalid on two grounds. First, the reasons recorded by the AO were vague and incomplete, lacking essential transaction details and demonstrating merely borrowed satisfaction rather than independent verification. Second, the PCIT's approval was deemed mechanical and invalid as it contained only the notation "yes, it is fit case" without recording any substantive satisfaction based on the facts presented. The Tribunal determined that both the reopening of assessment and the subsequent assessment framed by the AO were legally unsustainable, and accordingly allowed the assessee's appeal.
The ITAT quashed the reopening of assessment under section 147, finding it invalid on two grounds. First, the reasons recorded by the AO were vague and incomplete, lacking essential transaction details and demonstrating merely borrowed satisfaction rather than independent verification. Second, the PCIT's approval was deemed mechanical and invalid as it contained only the notation "yes, it is fit case" without recording any substantive satisfaction based on the facts presented. The Tribunal determined that both the reopening of assessment and the subsequent assessment framed by the AO were legally unsustainable, and accordingly allowed the assessee's appeal.
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