https://www.taxtmi.com/caselaws?id=759885 ITAT Kolkata quashed reassessment proceedings under section 147 finding the AO reopened assessment based on borrowed satisfaction without independent application of mind. The AO relied on information from Investigation wing stating an individual withdrew huge amounts, but bank statements showed only Rs. 9 lakh withdrawals. The court held there was no live link between tangible material and formation of reasons to believe income escaped assessment. The case was reopened for protective addition but substantive addition was made. Citing precedents from Delhi HC and SC, the tribunal ruled the reopening constituted impermissible fishing enquiry and allowed the assessee's appeal. en-us Tue, 08 Oct 2024 00:00:00 +0530 Wed, 09 Oct 2024 15:41:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=759885 ITAT Kolkata quashed reassessment proceedings under section 147 finding the AO reopened assessment based on borrowed satisfaction without independent application of mind. The AO relied on information from Investigation wing stating an individual withdrew huge amounts, but bank statements showed only Rs. 9 lakh withdrawals. The court held there was no live link between tangible material and formation of reasons to believe income escaped assessment. The case was reopened for protective addition but substantive addition was made. Citing precedents from Delhi HC and SC, the tribunal ruled the reopening constituted impermissible fishing enquiry and allowed the assessee's appeal. Case-Laws Income Tax Tue, 08 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=759885