Challenge to Tax Reassessment: AO Failed to Independently Verify Information, Violating Section 147 Requirements.

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....Reopening of assessment u/s 147 - non independent application of mind by AO - Borrowed satisfaction - A.O. has reopened the assessment solely on the basis of information received of the ADIT (Investigation) and without forming an independent opinion and there cannot be any reassessment for verification and without satisfying the requisite condition under the law. - AT....