https://www.taxtmi.com/caselaws?id=760397 ITAT Patna quashed reassessment proceedings u/s 147 initiated by AO without independent application of mind. The tribunal found AO relied on borrowed satisfaction from ADIT's investigation report without conducting independent enquiry or forming personal belief that income escaped assessment. Following Delhi HC precedents in SFIL Stock Broking Ltd. and Meenakshi Overseas Pvt. Ltd., tribunal held that mere reproduction of investigation conclusions without independent assessment constitutes borrowed satisfaction, invalidating reopening. Assessment and subsequent proceedings were quashed in assessee's favor. en-us Tue, 15 Oct 2024 00:00:00 +0530 Sat, 19 Oct 2024 12:09:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=760397 ITAT Patna quashed reassessment proceedings u/s 147 initiated by AO without independent application of mind. The tribunal found AO relied on borrowed satisfaction from ADIT's investigation report without conducting independent enquiry or forming personal belief that income escaped assessment. Following Delhi HC precedents in SFIL Stock Broking Ltd. and Meenakshi Overseas Pvt. Ltd., tribunal held that mere reproduction of investigation conclusions without independent assessment constitutes borrowed satisfaction, invalidating reopening. Assessment and subsequent proceedings were quashed in assessee's favor. Case-Laws Income Tax Tue, 15 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=760397