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    <title>2024 (2) TMI 1609 - GUJARAT HIGH COURT</title>
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    <description>HC quashed the reassessment proceedings initiated under section 148. It held that the Assessing Officer failed to record independent reasons for reopening and had merely relied on an investigation report from Kolkata regarding alleged bogus LTCG and shell company transactions. Such &quot;borrowed satisfaction&quot; without independent application of mind is impermissible in law. As the reasons were vague, nonspecific, and entirely dependent on the investigating agency&#039;s findings, the reopening of assessment was declared invalid. Consequently, the reassessment order and additions under section 68 were set aside in favour of the assessee.</description>
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    <pubDate>Mon, 26 Feb 2024 00:00:00 +0530</pubDate>
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      <title>2024 (2) TMI 1609 - GUJARAT HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=464936</link>
      <description>HC quashed the reassessment proceedings initiated under section 148. It held that the Assessing Officer failed to record independent reasons for reopening and had merely relied on an investigation report from Kolkata regarding alleged bogus LTCG and shell company transactions. Such &quot;borrowed satisfaction&quot; without independent application of mind is impermissible in law. As the reasons were vague, nonspecific, and entirely dependent on the investigating agency&#039;s findings, the reopening of assessment was declared invalid. Consequently, the reassessment order and additions under section 68 were set aside in favour of the assessee.</description>
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