https://www.taxtmi.com/caselaws?id=311455 The ITAT Amritsar quashed the reassessment proceedings under section 147, holding that the AO's reopening was based on borrowed satisfaction rather than independent application of mind. The AO merely relied on information from ITO(hq.) (tech) without conducting further enquiry to establish tangible material suggesting income escapement. The tribunal emphasized that "reasons to believe" requires more than "reasons to suspect" and cannot be based solely on information from another authority. The AO failed to quantify escaped income and acted on dictates rather than forming independent belief. The reassessment order was consequently quashed, and the assessee's appeal was allowed. en-us Thu, 16 Jan 2020 00:00:00 +0530 Wed, 27 Dec 2023 09:01:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=311455 The ITAT Amritsar quashed the reassessment proceedings under section 147, holding that the AO's reopening was based on borrowed satisfaction rather than independent application of mind. The AO merely relied on information from ITO(hq.) (tech) without conducting further enquiry to establish tangible material suggesting income escapement. The tribunal emphasized that "reasons to believe" requires more than "reasons to suspect" and cannot be based solely on information from another authority. The AO failed to quantify escaped income and acted on dictates rather than forming independent belief. The reassessment order was consequently quashed, and the assessee's appeal was allowed. Case-Laws Income Tax Thu, 16 Jan 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=311455