Reopening of assessment invalid without independent reasoned belief under Section 147; AO cannot rely solely on external information

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....The HC held that the reopening of assessment was invalid as the AO failed to form an independent reasoned belief and relied solely on information from the insight portal without verifying the material on record. The petitioner had disclosed all material facts and profits in the original return, accepted in the regular assessment under section 143(3). The AO's reliance on borrowed satisfaction and presumption of non-genuine profits, without independent verification or opinion, did not constitute valid grounds for reassessment. Consequently, the notice for reopening was quashed, affirming that reassessment cannot be initiated merely on information from external agencies or reports without forming a bona fide reasoned belief. The petitioner's appeal was allowed, and the reopening proceedings were set aside.....