https://www.taxtmi.com/caselaws?id=463062 The ITAT Kolkata held that the reopening of assessments u/s 147 for AYs 2011-12 to 2013-14 was invalid as the AO lacked a valid reason to believe undisclosed material facts. The AO relied solely on information from the Investigation Wing and a retracted statement without independent verification. The assessee had consistently disclosed all material facts, and prior assessments under s. 143(3) had accepted the transactions. The reassessment was based on borrowed satisfaction and change of opinion, which is impermissible. Consequently, the reassessment orders were quashed, and all additions were deleted. The assessee's appeal was allowed. en-us Mon, 26 Aug 2024 00:00:00 +0530 Mon, 04 Aug 2025 20:17:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=463062 The ITAT Kolkata held that the reopening of assessments u/s 147 for AYs 2011-12 to 2013-14 was invalid as the AO lacked a valid reason to believe undisclosed material facts. The AO relied solely on information from the Investigation Wing and a retracted statement without independent verification. The assessee had consistently disclosed all material facts, and prior assessments under s. 143(3) had accepted the transactions. The reassessment was based on borrowed satisfaction and change of opinion, which is impermissible. Consequently, the reassessment orders were quashed, and all additions were deleted. The assessee's appeal was allowed. Case-Laws Income Tax Mon, 26 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=463062