https://www.taxtmi.com/caselaws?id=446646 ITAT Rajkot held that reopening of assessment under Section 147 was invalid due to borrowed belief. AO relied solely on information from DCIT regarding alleged accommodation entry without independent verification or inquiry. AO failed to independently apply mind to determine if amounts were actually received by assessee or manner of receipt. The belief of income escapement was borrowed rather than AO's own independent assessment. Jurisdiction under Section 147 was deemed invalid without proper independent application of mind. Assessment reopening was quashed in favor of assessee. en-us Tue, 03 Oct 2023 00:00:00 +0530 Fri, 08 Dec 2023 08:56:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=446646 ITAT Rajkot held that reopening of assessment under Section 147 was invalid due to borrowed belief. AO relied solely on information from DCIT regarding alleged accommodation entry without independent verification or inquiry. AO failed to independently apply mind to determine if amounts were actually received by assessee or manner of receipt. The belief of income escapement was borrowed rather than AO's own independent assessment. Jurisdiction under Section 147 was deemed invalid without proper independent application of mind. Assessment reopening was quashed in favor of assessee. Case-Laws Income Tax Tue, 03 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=446646