https://www.taxtmi.com/caselaws?id=757841 ITAT Hyderabad quashed the reassessment notice u/s 148 and consequent assessment order u/s 143(3) r.w.s. 147, finding no live link between fresh tangible material and the AO's belief of income escapement. The AO issued the notice without independent verification, relying solely on information from another assessee's AO, constituting borrowed satisfaction. The reasons recorded showed discrepancies - initially claiming 4,17,535 shares but later assessing based on 2,22,222 shares, demonstrating lack of independent application of mind. The reopening was held invalid due to incorrect assumption of jurisdiction u/s 147. Assessee's appeal was allowed. en-us Wed, 14 Aug 2024 00:00:00 +0530 Tue, 03 Sep 2024 08:27:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=757841 ITAT Hyderabad quashed the reassessment notice u/s 148 and consequent assessment order u/s 143(3) r.w.s. 147, finding no live link between fresh tangible material and the AO's belief of income escapement. The AO issued the notice without independent verification, relying solely on information from another assessee's AO, constituting borrowed satisfaction. The reasons recorded showed discrepancies - initially claiming 4,17,535 shares but later assessing based on 2,22,222 shares, demonstrating lack of independent application of mind. The reopening was held invalid due to incorrect assumption of jurisdiction u/s 147. Assessee's appeal was allowed. Case-Laws Income Tax Wed, 14 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=757841