https://www.taxtmi.com/caselaws?id=434565 Reopening under s.147 was challenged on the ground that the AO acted on audit objections without independent application of mind. The HC held that an audit party's opinion on a question of law cannot substitute the AO's "reason to believe"; where the AO had expressly rejected the audit objections as unacceptable and yet issued notice, the initiation reflected borrowed satisfaction and a colourable exercise of jurisdiction. As no material indicated any subjective satisfaction or independent formation of belief by the AO, the reassessment notice was invalid, and the writ petition was allowed. en-us Mon, 20 Feb 2023 00:00:00 +0530 Wed, 07 Jan 2026 10:26:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=434565 Reopening under s.147 was challenged on the ground that the AO acted on audit objections without independent application of mind. The HC held that an audit party's opinion on a question of law cannot substitute the AO's "reason to believe"; where the AO had expressly rejected the audit objections as unacceptable and yet issued notice, the initiation reflected borrowed satisfaction and a colourable exercise of jurisdiction. As no material indicated any subjective satisfaction or independent formation of belief by the AO, the reassessment notice was invalid, and the writ petition was allowed. Case-Laws Income Tax Mon, 20 Feb 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=434565