https://www.taxtmi.com/caselaws?id=794157 Reopening of assessment under sections 147 and 148 was held invalid where the recorded reasons rested on incorrect factual premises about share capital, premium, and recipient entities. The Tribunal found borrowed satisfaction: the Assessing Officer relied on Investigation Wing information without independent application of mind, so the belief for reopening was defective. It also held that reopening could not be based only on search or survey statements without corroborative material. The reassessment was quashed and the consequential assessment was set aside. en-us Thu, 25 Jun 2026 00:00:00 +0530 Wed, 01 Jul 2026 08:47:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794157 Reopening of assessment under sections 147 and 148 was held invalid where the recorded reasons rested on incorrect factual premises about share capital, premium, and recipient entities. The Tribunal found borrowed satisfaction: the Assessing Officer relied on Investigation Wing information without independent application of mind, so the belief for reopening was defective. It also held that reopening could not be based only on search or survey statements without corroborative material. The reassessment was quashed and the consequential assessment was set aside. Case-Laws Income Tax Thu, 25 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794157