https://www.taxtmi.com/caselaws?id=755618 The ITAT Raipur held that the AO's reopening of assessment under section 147 was invalid due to lack of independent application of mind. The AO had recorded reasons based on information from the investigation wing claiming the assessee received commission as accommodation entries, but failed to verify the underlying facts. Bank statements showed no supporting evidence for the AO's conclusions. The tribunal found the AO acted mechanically on borrowed satisfaction without examining available material, making the reopening proceedings legally unsustainable. The assessee's appeal was allowed. en-us Fri, 12 Jul 2024 00:00:00 +0530 Sat, 13 Jul 2024 11:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=755618 The ITAT Raipur held that the AO's reopening of assessment under section 147 was invalid due to lack of independent application of mind. The AO had recorded reasons based on information from the investigation wing claiming the assessee received commission as accommodation entries, but failed to verify the underlying facts. Bank statements showed no supporting evidence for the AO's conclusions. The tribunal found the AO acted mechanically on borrowed satisfaction without examining available material, making the reopening proceedings legally unsustainable. The assessee's appeal was allowed. Case-Laws Income Tax Fri, 12 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755618