https://www.taxtmi.com/caselaws?id=772837 The ITAT Kolkata held that the reopening of assessment was invalid due to AO's failure to independently apply mind. The AO merely relied on information from DDIT (Investigation) regarding alleged accommodation entries without recording personal satisfaction or clear findings on income escapement. The reasons were based on presumptions rather than concrete evidence of tax evasion. Following precedent from M/s Sakaar Commercial Pvt. Ltd., the tribunal ruled that reopening based on borrowed satisfaction without independent reasoning constitutes nullity in law. The assessee's appeal was allowed, invalidating the reassessment proceedings. en-us Thu, 24 Apr 2025 00:00:00 +0530 Sat, 14 Jun 2025 06:47:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=772837 The ITAT Kolkata held that the reopening of assessment was invalid due to AO's failure to independently apply mind. The AO merely relied on information from DDIT (Investigation) regarding alleged accommodation entries without recording personal satisfaction or clear findings on income escapement. The reasons were based on presumptions rather than concrete evidence of tax evasion. Following precedent from M/s Sakaar Commercial Pvt. Ltd., the tribunal ruled that reopening based on borrowed satisfaction without independent reasoning constitutes nullity in law. The assessee's appeal was allowed, invalidating the reassessment proceedings. Case-Laws Income Tax Thu, 24 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=772837