https://www.taxtmi.com/caselaws?id=779500 ITAT DELHI - AT held that reopening under s.147 was invalid because the reasons to believe were mechanical, based solely on information from the Investigation Wing without independent application of mind by the AO, resulting in a borrowed satisfaction. Even though approval under s.151 was obtained, the AO failed to verify facts independently. The tribunal allowed the assessee's grounds and set aside the reassessment; the assessee's appeals were allowed. en-us Thu, 28 Aug 2025 00:00:00 +0530 Tue, 07 Oct 2025 08:30:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=779500 ITAT DELHI - AT held that reopening under s.147 was invalid because the reasons to believe were mechanical, based solely on information from the Investigation Wing without independent application of mind by the AO, resulting in a borrowed satisfaction. Even though approval under s.151 was obtained, the AO failed to verify facts independently. The tribunal allowed the assessee's grounds and set aside the reassessment; the assessee's appeals were allowed. Case-Laws Income Tax Thu, 28 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=779500