https://www.taxtmi.com/caselaws?id=791652 Reopening of assessment under section 147 requires the Assessing Officer's independent application of mind to tangible material; a mere reproduction of an investigation report amounts to borrowed satisfaction and is insufficient to assume jurisdiction. The reasons recorded must themselves show how the material justifies reopening, failing which the reopening is not supported. The text also notes an inordinate delay of 487 days in filing the Special Leave Petition, for which no plausible or bona fide explanation was offered, and the petition was dismissed on delay. en-us Thu, 30 Apr 2026 00:00:00 +0530 Thu, 14 May 2026 09:01:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791652 Reopening of assessment under section 147 requires the Assessing Officer's independent application of mind to tangible material; a mere reproduction of an investigation report amounts to borrowed satisfaction and is insufficient to assume jurisdiction. The reasons recorded must themselves show how the material justifies reopening, failing which the reopening is not supported. The text also notes an inordinate delay of 487 days in filing the Special Leave Petition, for which no plausible or bona fide explanation was offered, and the petition was dismissed on delay. Case-Laws Income Tax Thu, 30 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791652