https://www.taxtmi.com/caselaws?id=449490 The ITAT Kolkata held that reopening of assessment u/s 147 beyond four years was invalid due to procedural defects and lack of independent application of mind by the AO. The AO relied solely on information from investigation wing without examining the assessee's filed return, incorrectly described the nature of capital gains (confusing long term with short term), and failed to follow CBDT procedures for recording reasons. The tribunal found the reopening was based on "borrowed satisfaction" rather than proper analysis, as the assessee had already disclosed all relevant transactions in the original return. Appeal allowed. en-us Fri, 09 Feb 2024 00:00:00 +0530 Tue, 13 Feb 2024 07:44:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=449490 The ITAT Kolkata held that reopening of assessment u/s 147 beyond four years was invalid due to procedural defects and lack of independent application of mind by the AO. The AO relied solely on information from investigation wing without examining the assessee's filed return, incorrectly described the nature of capital gains (confusing long term with short term), and failed to follow CBDT procedures for recording reasons. The tribunal found the reopening was based on "borrowed satisfaction" rather than proper analysis, as the assessee had already disclosed all relevant transactions in the original return. Appeal allowed. Case-Laws Income Tax Fri, 09 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449490