https://www.taxtmi.com/caselaws?id=768304 The Bombay HC upheld ITAT's decision allowing the assessee's appeal against reassessment proceedings. The court found that the AO failed to independently apply his mind and acted under dictation from superiors, merely following TPO's determination from a subsequent assessment year. The AO issued the reopening notice without having independent reasons to believe income had escaped assessment, which is a mandatory precondition. The court concluded this constituted "borrowed satisfaction" vitiating the reassessment proceedings and decided against the revenue. en-us Tue, 01 Apr 2025 00:00:00 +0530 Fri, 04 Apr 2025 07:15:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=768304 The Bombay HC upheld ITAT's decision allowing the assessee's appeal against reassessment proceedings. The court found that the AO failed to independently apply his mind and acted under dictation from superiors, merely following TPO's determination from a subsequent assessment year. The AO issued the reopening notice without having independent reasons to believe income had escaped assessment, which is a mandatory precondition. The court concluded this constituted "borrowed satisfaction" vitiating the reassessment proceedings and decided against the revenue. Case-Laws Income Tax Tue, 01 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=768304