https://www.taxtmi.com/caselaws?id=442134 The Appellate Tribunal condoned the delay in filing the appeal due to logistical challenges and admitted it for adjudication. Regarding the validity of assessment proceedings under section 147 of the Income Tax Act, the Tribunal found that the Assessing Officer had not applied his own mind, leading to a case of borrowed satisfaction. Consequently, the Tribunal quashed the reopening of assessment. The penalty imposed under section 271(1)(c) was directed to be deleted as a consequential effect of quashing the assessment. The Tribunal ruled in favor of the appellant on both issues, allowing the appeals. en-us Tue, 22 Aug 2023 00:00:00 +0530 Fri, 25 Aug 2023 08:32:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=442134 The Appellate Tribunal condoned the delay in filing the appeal due to logistical challenges and admitted it for adjudication. Regarding the validity of assessment proceedings under section 147 of the Income Tax Act, the Tribunal found that the Assessing Officer had not applied his own mind, leading to a case of borrowed satisfaction. Consequently, the Tribunal quashed the reopening of assessment. The penalty imposed under section 271(1)(c) was directed to be deleted as a consequential effect of quashing the assessment. The Tribunal ruled in favor of the appellant on both issues, allowing the appeals. Case-Laws Income Tax Tue, 22 Aug 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=442134