https://www.taxtmi.com/caselaws?id=786493 Reopening an assessment under section 148 read with section 147 based solely on entries in documents seized from a third party, without an independent application of mind and where approval is mechanical or contradictory (borrowed satisfaction), is unsustainable; the reopening and the assessment order are quashed. Because the penalty under section 271(1)(c) was imposed consequentially on those reassessment additions, it lacks a valid foundation and is deleted. The Tribunal therefore allowed the appeals, setting aside the reassessment notices and orders and deleting the consequential penalty. en-us Wed, 11 Feb 2026 00:00:00 +0530 Thu, 12 Feb 2026 12:42:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=786493 Reopening an assessment under section 148 read with section 147 based solely on entries in documents seized from a third party, without an independent application of mind and where approval is mechanical or contradictory (borrowed satisfaction), is unsustainable; the reopening and the assessment order are quashed. Because the penalty under section 271(1)(c) was imposed consequentially on those reassessment additions, it lacks a valid foundation and is deleted. The Tribunal therefore allowed the appeals, setting aside the reassessment notices and orders and deleting the consequential penalty. Case-Laws Income Tax Wed, 11 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786493