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Reopening assessment u/s 147 based on borrowed satisfaction invalid; Section 68 additions unsustainable. Coordinate benches favor assessee.

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....Reopening of assessment u/s 147 - borrowed satisfaction v/s independent application of mind - addition u/s 68 - Action taken under section 147 on the basis of borrowed satisfaction is bad in law. Since the material for forming belief in the present case are similar to the material available in the aforesaid cases, and the coordinate Benches have decided the identical issue in favour of the assessee - AT....

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Reopening assessment u/s 147 based on borrowed satisfaction invalid; Section 68 additions unsustainable. Coordinate benches favor assessee.