https://www.taxtmi.com/caselaws?id=463268 ITAT (Del) held the reassessment invalid and quashed the reopening where the AO relied on an Investigation Wing report and recorded reasons based on incorrect facts without independent application of mind. The AO misattributed share-application receipts to a single source when records showed receipts from different companies, and the sanctioning authority approved mechanically. Following HC (Del) precedent, the Tribunal found the reopening amounted to borrowed satisfaction; therefore the reassessment proceedings were struck down and the assessee's appeal was allowed. en-us Mon, 07 Mar 2022 00:00:00 +0530 Wed, 20 Aug 2025 20:55:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=463268 ITAT (Del) held the reassessment invalid and quashed the reopening where the AO relied on an Investigation Wing report and recorded reasons based on incorrect facts without independent application of mind. The AO misattributed share-application receipts to a single source when records showed receipts from different companies, and the sanctioning authority approved mechanically. Following HC (Del) precedent, the Tribunal found the reopening amounted to borrowed satisfaction; therefore the reassessment proceedings were struck down and the assessee's appeal was allowed. Case-Laws Income Tax Mon, 07 Mar 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=463268