https://www.taxtmi.com/caselaws?id=771382 ITAT (Kol) held the reassessment reopening beyond four years invalid under the first proviso to s.147 where s.143(3) assessment existed because reasons recorded lacked any allegation of failure to disclose material facts; reopening quashed. The Tribunal also found the AO's reasons amounted to borrowed satisfaction-merely reproducing investigation material without independent application of mind or verification-so reopening under s.147 was unsustainable. Appeal allowed in favour of the assessee and reassessment order set aside. en-us Wed, 21 May 2025 00:00:00 +0530 Mon, 10 Nov 2025 11:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=771382 ITAT (Kol) held the reassessment reopening beyond four years invalid under the first proviso to s.147 where s.143(3) assessment existed because reasons recorded lacked any allegation of failure to disclose material facts; reopening quashed. The Tribunal also found the AO's reasons amounted to borrowed satisfaction-merely reproducing investigation material without independent application of mind or verification-so reopening under s.147 was unsustainable. Appeal allowed in favour of the assessee and reassessment order set aside. Case-Laws Income Tax Wed, 21 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=771382