https://www.taxtmi.com/caselaws?id=755225 The Gujarat HC quashed reassessment proceedings under section 147, ruling that the AO lacked valid reason to believe for reopening assessment regarding unexplained gold under section 69. The court held that gold ornaments were already recorded in petitioner's books and all details including quantity, stock, and purchase documents were submitted during original scrutiny under section 143(3). The AO merely relied on information from Investigation Unit without independent satisfaction, constituting impermissible borrowed satisfaction. Since no new or tangible material emerged and reassessment was based on change of opinion rather than fresh evidence, the proceedings were legally invalid. en-us Fri, 14 Jun 2024 00:00:00 +0530 Fri, 01 May 2026 17:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=755225 The Gujarat HC quashed reassessment proceedings under section 147, ruling that the AO lacked valid reason to believe for reopening assessment regarding unexplained gold under section 69. The court held that gold ornaments were already recorded in petitioner's books and all details including quantity, stock, and purchase documents were submitted during original scrutiny under section 143(3). The AO merely relied on information from Investigation Unit without independent satisfaction, constituting impermissible borrowed satisfaction. Since no new or tangible material emerged and reassessment was based on change of opinion rather than fresh evidence, the proceedings were legally invalid. Case-Laws Income Tax Fri, 14 Jun 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755225