https://www.taxtmi.com/caselaws?id=772353 ITAT Delhi allowed Revenue's appeal regarding validity of reassessment proceedings u/s 147. The Tribunal reversed CIT(A)'s order which had granted relief to assessee on grounds of borrowed satisfaction and improper approval u/s 151. ITAT held that AO had independent application of mind as he possessed sufficient information from search operations showing assessee's transactions with accommodation entry providers. The AO's decision to reopen assessment was based on clear facts indicating income escapement, not borrowed satisfaction. Regarding s.151 approval, ITAT found that detailed facts submitted to PCIT were sufficient for according proper approval without requiring further investigation. en-us Wed, 30 Apr 2025 00:00:00 +0530 Fri, 06 Jun 2025 12:05:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=772353 ITAT Delhi allowed Revenue's appeal regarding validity of reassessment proceedings u/s 147. The Tribunal reversed CIT(A)'s order which had granted relief to assessee on grounds of borrowed satisfaction and improper approval u/s 151. ITAT held that AO had independent application of mind as he possessed sufficient information from search operations showing assessee's transactions with accommodation entry providers. The AO's decision to reopen assessment was based on clear facts indicating income escapement, not borrowed satisfaction. Regarding s.151 approval, ITAT found that detailed facts submitted to PCIT were sufficient for according proper approval without requiring further investigation. Case-Laws Income Tax Wed, 30 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=772353