https://www.taxtmi.com/caselaws?id=784713 Reopening under s.147 was held invalid because the AO acted on borrowed satisfaction, merely reproducing generalized Investigation Wing information without independent verification, and the s.148A(b) notice was ambiguous as to whether the alleged transaction was sales or purchases and even misstated the quantum, showing no live and rational nexus between material and belief of escapement; consequently, reassessment and the consequential additions were quashed. Separately, the estimated 2% "commission" addition on alleged bogus sales was deleted as sales were recorded, supported by statutory/GST compliance, and the Revenue produced no tangible evidence of accommodation entry benefits or fund flow. The disallowance of alleged bogus purchases was deleted since purchases were supported by invoices and banking payments, stock/quantitative records matched, and a mere HSN classification difference with identical GST rate did not prove non-genuineness. en-us Wed, 07 Jan 2026 00:00:00 +0530 Sat, 10 Jan 2026 08:25:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784713 Reopening under s.147 was held invalid because the AO acted on borrowed satisfaction, merely reproducing generalized Investigation Wing information without independent verification, and the s.148A(b) notice was ambiguous as to whether the alleged transaction was sales or purchases and even misstated the quantum, showing no live and rational nexus between material and belief of escapement; consequently, reassessment and the consequential additions were quashed. Separately, the estimated 2% "commission" addition on alleged bogus sales was deleted as sales were recorded, supported by statutory/GST compliance, and the Revenue produced no tangible evidence of accommodation entry benefits or fund flow. The disallowance of alleged bogus purchases was deleted since purchases were supported by invoices and banking payments, stock/quantitative records matched, and a mere HSN classification difference with identical GST rate did not prove non-genuineness. Case-Laws Income Tax Wed, 07 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784713