https://www.taxtmi.com/caselaws?id=767623 Gujarat HC set aside reassessment proceedings u/s 147 for lack of valid reasons to believe. The AO mechanically recorded reasons without independent application of mind, treating total debit and credit entries from books as escaped income. The court found no rational nexus established between transactions and alleged income escapement. The AO failed to properly consider investigation wing reports and recorded reasons based on borrowed satisfaction rather than forming independent opinion. Reassessment notices were issued in mechanical manner contrary to available information, making assumption of jurisdiction invalid under established precedents. en-us Mon, 10 Mar 2025 00:00:00 +0530 Fri, 21 Mar 2025 08:25:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767623 Gujarat HC set aside reassessment proceedings u/s 147 for lack of valid reasons to believe. The AO mechanically recorded reasons without independent application of mind, treating total debit and credit entries from books as escaped income. The court found no rational nexus established between transactions and alleged income escapement. The AO failed to properly consider investigation wing reports and recorded reasons based on borrowed satisfaction rather than forming independent opinion. Reassessment notices were issued in mechanical manner contrary to available information, making assumption of jurisdiction invalid under established precedents. Case-Laws Income Tax Mon, 10 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767623