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    <title>2021 (11) TMI 379 - ITAT MUMBAI</title>
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    <description>The Tribunal found the reassessment jurisdiction under section 148 challenged for AY 2009-10 to be invalid due to legal infirmities in the notice issued by the Assessing Officer. The AO&#039;s reliance on borrowed facts, notice issuance beyond the limitation period, and lack of independent belief were cited as reasons for the challenge. The Tribunal determined that the reopening lacked proper jurisdiction, as it was based on borrowed satisfaction without the AO&#039;s independent application of mind. Consequently, the assessment was quashed, deeming it bad in law, and the appeal was allowed on 28th October 2021.</description>
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      <title>2021 (11) TMI 379 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=414598</link>
      <description>The Tribunal found the reassessment jurisdiction under section 148 challenged for AY 2009-10 to be invalid due to legal infirmities in the notice issued by the Assessing Officer. The AO&#039;s reliance on borrowed facts, notice issuance beyond the limitation period, and lack of independent belief were cited as reasons for the challenge. The Tribunal determined that the reopening lacked proper jurisdiction, as it was based on borrowed satisfaction without the AO&#039;s independent application of mind. Consequently, the assessment was quashed, deeming it bad in law, and the appeal was allowed on 28th October 2021.</description>
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