https://www.taxtmi.com/caselaws?id=782425 ITAT Kolkata allowed the assessee's appeal and quashed the reassessment proceedings and consequent order. It held that the reopening under section 147/148 was invalid as the reasons recorded did not mention obtaining the mandatory sanction/approval under section 151, indicating a mechanical exercise without proper application of mind. ITAT further found that the reasons constituted mere suspicion regarding the creditworthiness of a loan creditor and lacked a live link with alleged income escapement, being vague and ambiguous. The AO had acted on borrowed satisfaction without independent inquiry, rendering the reopening and assessment legally unsustainable. en-us Tue, 28 Oct 2025 00:00:00 +0530 Sat, 29 Nov 2025 07:57:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782425 ITAT Kolkata allowed the assessee's appeal and quashed the reassessment proceedings and consequent order. It held that the reopening under section 147/148 was invalid as the reasons recorded did not mention obtaining the mandatory sanction/approval under section 151, indicating a mechanical exercise without proper application of mind. ITAT further found that the reasons constituted mere suspicion regarding the creditworthiness of a loan creditor and lacked a live link with alleged income escapement, being vague and ambiguous. The AO had acted on borrowed satisfaction without independent inquiry, rendering the reopening and assessment legally unsustainable. Case-Laws Income Tax Tue, 28 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782425