https://www.taxtmi.com/caselaws?id=785067 Issue 1 - Validity of reopening under ss.147/148 based on "borrowed satisfaction": ITAT found the reasons recorded by the AO were cryptic, vague and merely reflected information from the investigation wing without independent application of mind or a live link between tangible material and the formation of belief; consequently the reopening was held to be founded on borrowed satisfaction and invalid. Outcome: notice u/s 148 and reassessment framed thereunder quashed. Issue 2 - Limitation: ITAT held the assessment order must leave the AO's control within the limitation period; the order dated 31.03.2022 was served after that date and thus was beyond the permissible timeline. Outcome: assessment order barred by limitation and invalid. en-us Tue, 13 Jan 2026 00:00:00 +0530 Fri, 16 Jan 2026 08:03:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785067 Issue 1 - Validity of reopening under ss.147/148 based on "borrowed satisfaction": ITAT found the reasons recorded by the AO were cryptic, vague and merely reflected information from the investigation wing without independent application of mind or a live link between tangible material and the formation of belief; consequently the reopening was held to be founded on borrowed satisfaction and invalid. Outcome: notice u/s 148 and reassessment framed thereunder quashed. Issue 2 - Limitation: ITAT held the assessment order must leave the AO's control within the limitation period; the order dated 31.03.2022 was served after that date and thus was beyond the permissible timeline. Outcome: assessment order barred by limitation and invalid. Case-Laws Income Tax Tue, 13 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785067