https://www.taxtmi.com/caselaws?id=765858 ITAT Delhi held that reopening assessment under section 147 based solely on ADIT (Inv.) report without independent application of mind constitutes borrowed satisfaction and is illegal. The AO merely reproduced investigation conclusions without establishing crucial link between available information and belief that income escaped assessment. The court noted AO ignored assessee's exempt income of Rs. 15,26,571/- while focusing only on other sources income. On merits, creditor transactions through banking channels with proper documentation could not be treated as unexplained credits under section 68. Assessee's appeal was allowed. en-us Fri, 07 Feb 2025 00:00:00 +0530 Tue, 11 Feb 2025 07:18:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=765858 ITAT Delhi held that reopening assessment under section 147 based solely on ADIT (Inv.) report without independent application of mind constitutes borrowed satisfaction and is illegal. The AO merely reproduced investigation conclusions without establishing crucial link between available information and belief that income escaped assessment. The court noted AO ignored assessee's exempt income of Rs. 15,26,571/- while focusing only on other sources income. On merits, creditor transactions through banking channels with proper documentation could not be treated as unexplained credits under section 68. Assessee's appeal was allowed. Case-Laws Income Tax Fri, 07 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=765858