https://www.taxtmi.com/caselaws?id=450956 The HC quashed a reassessment notice issued beyond four years after assessment completion under Section 143(3). The AO reopened assessment based on DG GST investigation findings that two entities lacked assets/inventories and engaged in fraudulent transactions. However, the assessee had disclosed the loan transaction with one entity in Form 3CD and balance sheet. The court held the AO acted on borrowed satisfaction without independent examination, showing non-application of mind. Since material facts were fully disclosed originally, reopening was barred under Section 147 proviso. The notice was invalid due to lack of AO's independent satisfaction and failure to examine disclosed information. en-us Tue, 12 Mar 2024 00:00:00 +0530 Wed, 09 Jul 2025 16:33:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=450956 The HC quashed a reassessment notice issued beyond four years after assessment completion under Section 143(3). The AO reopened assessment based on DG GST investigation findings that two entities lacked assets/inventories and engaged in fraudulent transactions. However, the assessee had disclosed the loan transaction with one entity in Form 3CD and balance sheet. The court held the AO acted on borrowed satisfaction without independent examination, showing non-application of mind. Since material facts were fully disclosed originally, reopening was barred under Section 147 proviso. The notice was invalid due to lack of AO's independent satisfaction and failure to examine disclosed information. Case-Laws Income Tax Tue, 12 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=450956