https://www.taxtmi.com/caselaws?id=766963 The ITAT Guwahati quashed reassessment proceedings under section 147 initiated after four years, finding the reopening was based on poor reasons and borrowed satisfaction without independent application of mind by the AO. The tribunal noted contradictory information in the AO's reasons, where accommodation entries were allegedly received by the assessee in FY 2010-11 but actually pertained to another company in FY 2008-09. The AO failed to conduct proper enquiry by examining returns and audited balance sheets before forming reasons to believe. The tribunal upheld the CIT(A)'s decision declaring the reassessment illegal and dismissed all revenue grounds. en-us Tue, 03 Sep 2024 00:00:00 +0530 Fri, 07 Mar 2025 08:41:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=766963 The ITAT Guwahati quashed reassessment proceedings under section 147 initiated after four years, finding the reopening was based on poor reasons and borrowed satisfaction without independent application of mind by the AO. The tribunal noted contradictory information in the AO's reasons, where accommodation entries were allegedly received by the assessee in FY 2010-11 but actually pertained to another company in FY 2008-09. The AO failed to conduct proper enquiry by examining returns and audited balance sheets before forming reasons to believe. The tribunal upheld the CIT(A)'s decision declaring the reassessment illegal and dismissed all revenue grounds. Case-Laws Income Tax Tue, 03 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=766963