https://www.taxtmi.com/caselaws?id=774437 ITAT Delhi dismissed revenue's appeal challenging CIT(A)'s order quashing reassessment proceedings u/s 147. The AO issued notice u/s 148 based solely on statements recorded by Investigation Wing from alleged entry operators, constituting borrowed satisfaction without independent application of mind. The statements were not provided to assessee in readable format. Impounded documents during survey were unrelated to assessment year. CIT(A) correctly deleted additions for share capital/premium, sundry creditors, and estimated profit of Rs. 50 lakhs. AO improperly rejected books u/s 145(3) while making additions based on same books. Reassessment proceedings were rightly quashed due to borrowed satisfaction and insufficient material. en-us Thu, 15 May 2025 00:00:00 +0530 Wed, 09 Jul 2025 08:50:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774437 ITAT Delhi dismissed revenue's appeal challenging CIT(A)'s order quashing reassessment proceedings u/s 147. The AO issued notice u/s 148 based solely on statements recorded by Investigation Wing from alleged entry operators, constituting borrowed satisfaction without independent application of mind. The statements were not provided to assessee in readable format. Impounded documents during survey were unrelated to assessment year. CIT(A) correctly deleted additions for share capital/premium, sundry creditors, and estimated profit of Rs. 50 lakhs. AO improperly rejected books u/s 145(3) while making additions based on same books. Reassessment proceedings were rightly quashed due to borrowed satisfaction and insufficient material. Case-Laws Income Tax Thu, 15 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774437