Reopening Tax Assessment u/s 147 Invalid Without Independent Reason, Petitioner's Challenge Succeeds Due to Improper Application.

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....Validity of Reopening of assessment u/s 147 - independent' v/s 'borrowed' or 'dictated' satisfaction - The authority is sufficiently couched with the power of revision u/s 263 and as such when the authority has resorted to Section 147 is appearing to be impermissible especially when there appears to be no subjective satisfaction independently arrived at that any income chargeable to tax has escaped the assessment for any assessment year. This reason to belief contemplated u/s 147 of the Act requires proper application before initiating the step which here appearing to be missing and as such we are quite satisfied that case is made out by the petitioner to call for any interference. - HC....