https://www.taxtmi.com/highlights?id=96859 Reopening an income tax assessment based solely on entries found in loose papers seized from a third party amounts to 'borrowed satisfaction' and cannot independently justify proceedings. The decision reasons that statutory presumptions apply only against the person from whose possession documents were seized, and third party possession is at best corroborative, not substantive, evidence; accordingly, a re opening founded only on such third party entries is invalid. Applying this principle, the tribunal held the notice under section 148 unlawful and quashed the consequent reassessment under section 147, allowing the taxpayer's appeal. en-us Fri, 13 Feb 2026 14:20:55 +0530 Fri, 13 Feb 2026 14:20:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=96859 Reopening an income tax assessment based solely on entries found in loose papers seized from a third party amounts to 'borrowed satisfaction' and cannot independently justify proceedings. The decision reasons that statutory presumptions apply only against the person from whose possession documents were seized, and third party possession is at best corroborative, not substantive, evidence; accordingly, a re opening founded only on such third party entries is invalid. Applying this principle, the tribunal held the notice under section 148 unlawful and quashed the consequent reassessment under section 147, allowing the taxpayer's appeal. Highlights Income Tax Fri, 13 Feb 2026 14:20:55 +0530 https://www.taxtmi.com/highlights?id=96859