https://www.taxtmi.com/caselaws?id=764946 The Gujarat HC held that the AO failed to reopen assessment under section 147 due to inadequate reasons recorded. The AO merely relied on borrowed satisfaction from search operations at Kushal Group and Insight Portal information showing petitioners as beneficiaries of accommodation entries and unsecured loans, without establishing any live-link between this information and petitioners' records. The court found the AO did not form independent satisfaction or prima-facie belief that income escaped assessment, as required reasons lacked requisite details connecting the external information to actual tax evasion by the assessees. en-us Tue, 07 Jan 2025 00:00:00 +0530 Mon, 20 Jan 2025 17:27:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=764946 The Gujarat HC held that the AO failed to reopen assessment under section 147 due to inadequate reasons recorded. The AO merely relied on borrowed satisfaction from search operations at Kushal Group and Insight Portal information showing petitioners as beneficiaries of accommodation entries and unsecured loans, without establishing any live-link between this information and petitioners' records. The court found the AO did not form independent satisfaction or prima-facie belief that income escaped assessment, as required reasons lacked requisite details connecting the external information to actual tax evasion by the assessees. Case-Laws Income Tax Tue, 07 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=764946