https://www.taxtmi.com/caselaws?id=784620 Reopening of assessment under s.147 based on audit objections was challenged as lacking the AO's independent application of mind and amounting to borrowed satisfaction. The HC found no material indicating the AO's subjective satisfaction; instead, the notice was issued solely at the audit party's instance, rendering the reassessment a colourable exercise of jurisdiction and invalid. The SC declined to interfere with the HC's finding and dismissed the special leave petition, thereby sustaining the quashing of the reopening. en-us Tue, 06 Jan 2026 00:00:00 +0530 Thu, 08 Jan 2026 08:22:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784620 Reopening of assessment under s.147 based on audit objections was challenged as lacking the AO's independent application of mind and amounting to borrowed satisfaction. The HC found no material indicating the AO's subjective satisfaction; instead, the notice was issued solely at the audit party's instance, rendering the reassessment a colourable exercise of jurisdiction and invalid. The SC declined to interfere with the HC's finding and dismissed the special leave petition, thereby sustaining the quashing of the reopening. Case-Laws Income Tax Tue, 06 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784620