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“borrowed satisfaction”

ReassessmentSection 147Section 1471,326 judgments

The decision most relied on for borrowed satisfaction is PCIT v. Meenakshi Overseas Pvt. Ltd. (395 ITR 677), cited in 471 judgments on BharatTax.

Leading authorities on borrowed satisfaction

PCIT v. Meenakshi Overseas Pvt. Ltd.
395 ITR 677 · 2017 · High Court
471
citing judgments

Reassessment proceedings initiated solely based on an investigation wing/appraisal report, without the Assessing Officer's independent application of mind to form a 'reason to believe' that income has escaped assessment, are beyond jurisdiction, bad in law, and void ab initio.

394 ITR 146 (Guj.) 2. Varshaben S. Patel v. ITO
338 ITR 51 · 2011 · High Court
295
citing judgments

Reasons for reopening an assessment must be specific and not vague, scanty, or based on borrowed satisfaction. The Assessing Officer must quantify the escaped income.

222 Taxman 15 (Gujarat)(MAG.), Principal Commissioner of Income-tax-4 v. G & G Pharma India Ltd.
384 ITR 147 · 2016 · High Court
274
citing judgments

An assessment can be reopened if there is tangible material indicating escapement of income, demonstrating a live link between the material and the reasons recorded for reopening. The Assessing Officer must apply their mind to the material facts, and the sanction under section 151 should not be based on borrowed satisfaction.

CIT v. SFIL Stock Broking Ltd.
325 ITR 285 · 2010 · High Court
243
citing judgments

Reassessment proceedings under Section 147 are invalid and void ab initio if initiated based on 'borrowed satisfaction' without the Assessing Officer's independent application of mind, or merely on documents already available on record without fresh tangible material.

Sarthak Securities Co. Pvt. Ltd. v. ITO
329 ITR 110 · 2010 · High Court
217
citing judgments

Reassessment proceedings under Section 147 are invalid if the Assessing Officer records satisfaction based on borrowed satisfaction or information without independently applying their mind and forming their own 'reason to believe' that income has escaped assessment. The AO must arrive at an independent conclusion, not merely act on a report from an investigation wing without due diligence.

ITO v. Selected Dalurband Coal Co. (P.) Ltd.
217 ITR 597 · 1996 · Supreme Court
180
citing judgments

The Assessing Officer's belief that income has escaped assessment, leading to the reopening of an assessment, is a matter of subjective satisfaction. The materials available at the time of forming this belief do not need to conclusively prove the escapement of income.

CIT v. SPL’s Siddhartha Ltd.
345 ITR 223 · 2012 · High Court
164
citing judgments

Reassessment proceedings under Section 147 are invalid if the sanction required under Section 151 is obtained mechanically, without independent application of mind by the sanctioning authority, or is based on borrowed satisfaction.

CIT v. Atul Jain
299 ITR 383 · 2008 · High Court
147
citing judgments

Reassessment proceedings under section 147 are not valid if the information relied upon by the Assessing Officer is vague, scanty, and lacks specific details linking it to the assessee's transactions.

Judgments citing borrowed satisfaction

Bhavna Shetalkumar Patel, Ahmedabad vs. The Dy.CIT, Circle-3(1)(1), Ahmedabad

In the result, the appeal of the assessee stands allowed

ITA 1103/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad05 Dec 2025AY 2016-17

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokar

For Appellant: Shri Parin S Shah, ARFor Respondent: Shri Santosh Kumar, Sr. DR
Section 10(38)Section 142(1)Section 143(1)Section 144Section 144BSection 147Section 148Section 68

objected to the reopening on the grounds that the transaction had been fully disclosed in the original return, that the reopening was based on borrowed satisfaction and that no material relating to the assessee was furnished. These objections were rejected by the Assessing Officer. 8. The assessment was completed under

The DCIT-Circle-4(1)(1), Ahmedabad vs. Shree Siddhi Infrabuild Pvt. Ltd, Ahmedabad

ITA 1637/AHD/2019[2014-15]Status: DisposedITAT Ahmedabad05 Dec 2025AY 2014-15

Bench: Shri Sanjay Garg & Makarand V. Mahadeokar

For Appellant: Shri Shrunjal Shah, ARFor Respondent: Shri R.P. Rastogi, CIT-DR
Section 143(3)Section 147Section 148Section 68Section 69A

also submitted that the copy of RTI reply dated 20.08.2024 suggest that the Assessing Officer has not applied independent mind and relied on the borrowed satisfaction. The same grounds are admitted. 5.1 On merits, the Authorised Representative (AR) reiterated the factual matrix as recorded by the lower authorities and invited ... reply dated 20.08.2024 placed on record, the Assessing Officer had not applied his independent mind while recording reasons and had merely acted on borrowed satisfaction. However, in view of our decision on the merits of the additions in favour of the assessee, these legal grounds do not call for adjudication

The DCIT-Circle-4(1)(1), Ahmedabad vs. Shree Siddhi Infrabuild Pvt. Ltd, Ahmedabad

ITA 1636/AHD/2019[2012-13]Status: DisposedITAT Ahmedabad05 Dec 2025AY 2012-13

Bench: Shri Sanjay Garg & Makarand V. Mahadeokar

For Appellant: Revenue by Shri R.P. Rastogi, CIT-DR
Section 143(3)Section 147Section 148Section 68Section 69A

also submitted that the copy of RTI reply dated 20.08.2024 suggest that the Assessing Officer has not applied independent mind and relied on the borrowed satisfaction. The same grounds are admitted. 5.1 On merits, the Authorised Representative (AR) reiterated the factual matrix as recorded by the lower authorities and invited ... reply dated 20.08.2024 placed on record, the Assessing Officer had not applied his independent mind while recording reasons and had merely acted on borrowed satisfaction. However, in view of our decision on the merits of the additions in favour of the ITA Nos. 1635 to 1637/Ahd/2019 Asst. Years

The DCIT-Circle-4(1)(1), Ahmedabad vs. Shree Siddhi Infrabuild Pvt. Ltd, Ahmedabad

ITA 1635/AHD/2019[2011-12]Status: DisposedITAT Ahmedabad05 Dec 2025AY 2011-12

Bench: Shri Sanjay Garg & Makarand V. Mahadeokar

For Appellant: Revenue by Shri R.P. Rastogi, CIT-DR
Section 143(3)Section 147Section 148Section 68Section 69A

also submitted that the copy of RTI reply dated 20.08.2024 suggest that the Assessing Officer has not applied independent mind and relied on the borrowed satisfaction. The same grounds are admitted. 5.1 On merits, the Authorised Representative (AR) reiterated the factual matrix as recorded by the lower authorities and invited ... reply dated 20.08.2024 placed on record, the Assessing Officer had not applied his independent mind while recording reasons and had merely acted on borrowed satisfaction. However, in view of our decision on the merits of the additions in favour of the ITA Nos. 1635 to 1637/Ahd/2019 Asst. Years

Anil Kumar HUF, Delhi vs. Income Tax Officer Ward 35(5), Delhi

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 737/DEL/2025[2013-14]Status: DisposedITAT Delhi05 Dec 2025AY 2013-14

Bench: Shri M. Balaganesh & Shri Sudhir Kumaranil Kumar Huf, Vs. Ito, 2639/4, Naya Bazar, Ward-35(5), Delhi Delhi (Appellant) (Respondent) Pan: Aacha6188H Assessee By : Shri Pranshu Singhal, Ca Shri Rahul Bhardwaj, Adv Revenue By: Shri Om Prakash, Sr. Dr Date Of Hearing 08/09/2025 Date Of Pronouncement 05/12/2025

For Appellant: Shri Pranshu Singhal, CAFor Respondent: Shri Om Prakash, Sr. DR
Section 143(3)Section 147Section 151Section 69C

quashed as the same has been reopened on the basis of the reasons which are vague and has been recorded only on borrowed satisfaction. 3. On the facts and circumstances of the case, the Ld. CIT(A) has erred in confirming the order of the AO despite the fact that

Diamond Realcon Private Limited, Delhi vs. ACIT, Central Circle-2, Faridabad

In the result, Appeal in ITA

ITA 1260/DEL/2025[2012-13]Status: DisposedITAT Delhi05 Dec 2025AY 2012-13

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Ita No. 1260/Del/2025 (A.Y. 2012-13) M/S Diamond Realcon Private Vs Assistant Commissioner Of Limited, Income Tax, Central Circle-Ii, Shop No. 68, Building No. 38, Faridabad, Surya House, Near Pnb, Devli, Haryana-121001 Khanpur, New Delhi-110062 Pan: Aadcd6696H Appellant Respondent Assessee By Sh. S. S. Nagar, Ca Revenue By Ms.Suman Malik, Cit Dr Date Of Hearing 08/09/2025 Date Of Pronouncement 05/12/2025

Section 143(2)Section 147Section 148Section 151Section 153CSection 68

that the reasons to believe recorded by the Ld. AO for the initiation of reassessment proceedings u/s 147 of the Act was based on borrowed satisfaction and without application of mind. Diamond Realcon Pvt. Ltd. Vs. ACIT 6.2 That on the facts and in the circumstances of the case ... that the reasons to believe recorded by the Ld. AO for the initiation of reassessment proceedings u/s 147 of the Act was based on borrowed satisfaction and without application of mind. 6.2 That on the facts and in the circumstances of the case, the Ld. CIT-(A) has erred

Diamond Realcon Private Limited, New Delhi vs. ACIT, Central Circle-2, Faridabad

In the result, Appeal in ITA

ITA 1259/DEL/2025[2011-12]Status: DisposedITAT Delhi05 Dec 2025AY 2011-12

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Ita No. 1260/Del/2025 (A.Y. 2012-13) M/S Diamond Realcon Private Vs Assistant Commissioner Of Limited, Income Tax, Central Circle-Ii, Shop No. 68, Building No. 38, Faridabad, Surya House, Near Pnb, Devli, Haryana-121001 Khanpur, New Delhi-110062 Pan: Aadcd6696H Appellant Respondent Assessee By Sh. S. S. Nagar, Ca Revenue By Ms.Suman Malik, Cit Dr Date Of Hearing 08/09/2025 Date Of Pronouncement 05/12/2025

Section 143(2)Section 147Section 148Section 151Section 153CSection 68

that the reasons to believe recorded by the Ld. AO for the initiation of reassessment proceedings u/s 147 of the Act was based on borrowed satisfaction and without application of mind. Diamond Realcon Pvt. Ltd. Vs. ACIT 6.2 That on the facts and in the circumstances of the case ... that the reasons to believe recorded by the Ld. AO for the initiation of reassessment proceedings u/s 147 of the Act was based on borrowed satisfaction and without application of mind. 6.2 That on the facts and in the circumstances of the case, the Ld. CIT-(A) has erred

Imran Ahmad, Moradabad, Uttar Pradesh vs. Income Tax Officer, Moradabad

Appeal is partly allowed

ITA 3490/DEL/2025[2013-2014]Status: DisposedITAT Delhi03 Dec 2025AY 2013-2014
Section 139Section 147Section 148

from CCE which was passed on to revenue authorities was 'tangible material outside record' to initiate valid reassessment proceedings. Thus there was no borrowed satisfaction on the part of the AO. There was independent application of mind on the part of the AO. 14. Reliance is also placed upon

Viraj Software Pvt. Ltd., Delhi vs. ITO, Ward-26(4), Delhi

Appeal is dismissed

ITA 1084/DEL/2025[2012-13]Status: DisposedITAT Delhi03 Dec 2025AY 2012-13

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2012-13 M/S. Viraj Software Pvt. Vs. Income Tax Officer, Ltd., Ward-26(4), 28, Raja Garden, New Delhi New Delhi Pan: Aaccv5229M (Appellant) (Respondent) Assessee By None Department By Ms. Ankush Kalra, Sr. Dr

Section 142(1)Section 143(1)Section 143(2)Section 144Section 147Section 148Section 68Section 69C

another aspect also to formation of the belief and that is the satisfaction should be the own satisfaction of the AO and not the borrowed satisfaction. If the AO re-opens an assessment simply on the basis of satisfaction recorded by some other authority like Sales Tax, Excise or Director

Manoj Anand, Guwahati vs. ITO W-2(2) Ghy, Guwahati

In the result, the appeal of the assessee is allowed

ITA 273/GTY/2024[2018-19]Status: DisposedITAT Guwahati02 Dec 2025AY 2018-19

Bench: Shri Rajesh Kumar, Am & Shri Manomohan Das, Jm Manoj Anand Ito W-2(2), Ghy Flat 4D, Garima Grand, Aaykar Bhawan, Christian Basti, Departmental Representative B. G.S. Road, Guwahati-781005, Vs. Baruah Road, Guwahati-781007, Assam Assam (Appellant) (Respondent) Pan No. Agbpa9883C

For Appellant: Shri Miraj D Shah, ARFor Respondent: Shri Sanjay Jha, DR
Section 144BSection 147Section 148Section 68

authorities below. We further note that no enquiry has been conducted into the documents/evidences furnished by the assessee. The reassessment itself is based on borrowed satisfaction arising merely from FIU alerts and Investigation Wing references, without any application of mind to the assessee's own facts or records. Moreover

Income-Tax Officer, Ward-1(2)(3), Ahmedabad, Aayakar Bhawan, Vejalpur vs. Jasmine Jayantibhai Sanghavi, Ahmedabad

In the result, appeal of the Revenue is dismissed

ITA 1779/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad02 Dec 2025AY 2016-17

Bench: Ms. Suchitra Raghunath Kambleआयकर अपील सं./I.T.A. No. 1779/Ahd/2025 (िनधा"रण वष" / Assessment Year : 2016-17) बनाम/ Income-Tax Officer Jasmine Jayantibhai Ward-1(2)(3), Ahmedabad Sanghavi Vs. 7-F, Swetal Flat, Khanpur Bai Centre, Khanpur, Ahmedabad, Gujarat - 380001 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aqcps1433R (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : Shri Suresh Chand Meena, Sr. Dr ""यथ" क" ओर से/Respondent By : Shri Sunil Talati, Ar Date Of Hearing 01/12/2025 02/12/2025 Date Of Pronouncement O R D E R The Appeal Is Filed By The Revenue Against The Order Dated 08.08.2025 Passed By The National Faceless Appeal Centre (Nfac), Delhi, For Assessment Year 2016-17. 2. The Grounds Of Appeal Filed By The Revenue Are As Under:

For Appellant: Shri Suresh Chand Meena, Sr. DRFor Respondent: Shri Sunil Talati, AR
Section 133ASection 142(1)Section 147Section 148Section 69ASection 69C

erred in law and on facts in holding that the reassessment proceedings initiated vide notice u/s 148 dated 30.03.2021 were based on "borrowed satisfaction" and were hence invalid, without appreciating that the information received from the investigation Wing, which was specific, reliable and based on material unearthed during a survey

Deputy Commissioner of Income Tax, Circle-1, Tirupur vs. Loocust Incorp, Tirupur

In the result, appeal of the assessee vide CO Nos

ITA 1695/CHNY/2025[2016-17]Status: DisposedITAT Chennai02 Dec 2025AY 2016-17

Bench: Shri Ss Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.1692, 1693, 1694 & 1695 / Chny/2025 Assessment Years-2013-14, 2014-15, 2015-16 & 2016-17 Deputy Commissioner Of Income Tax, Loocust Incorp, No.28A, Mgr Nagar, 14Th Street, Circle-1(1) Tirupur. Pn Road, Tirupur, Tamil Nadu-641 602. [Pan: Aabfl6721C] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपील सं./Co Nos.-77, 78, 79 & 80 / Chny/2025, Assessment Years-2013-14, 2014-15, 2015-16 & 2016-17 Loocust Incorp, Deputy Commissioner Of Income Tax, No.28A, Mgr Nagar, 14Th Street, Circle-1(1) Pn Road, Tirupur, Tirupur. Tamil Nadu-641 602. [Pan: Aabfl6721C] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By : Mr.T.Banusekar, Advocate प्रत्यर्थी की ओर से /Revenue By : Mr.Shiva Srinivas, Cit सुनवाई की तारीख/Date Of Hearing : 08.10.2025 घोषणा की तारीख /Date Of Pronouncement : 02.12.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

For Appellant: Mr.T.Banusekar, AdvocateFor Respondent: Mr.Shiva Srinivas, CIT
Section 132Section 143(3)

80/Chny/2025 a) As the very issue of notice u/s. 148 was based ONLY on the information from the JCIT(OSD), Mumbai, It amounted to borrowed satisfaction, exhibiting non- application of mind. b) As notice u/s. 148 dt. 30/03/2021 is not valid in so far as the date of service ... Income Tax for reopening the assessment is without application of mind. 3. For that the assessment was reopened only on the basis of borrowed satisfaction and therefore the reopening was without application of mine. Addition of Rs.2,39,90,590/- being purported bogus purchases 1. For that the Assessing Officer

Deputy Commissioner of Income Tax, Circle-1, Tirupur vs. Loocust Incorp, Tirupur

In the result, appeal of the assessee vide CO Nos

ITA 1694/CHNY/2025[2015-16]Status: DisposedITAT Chennai02 Dec 2025AY 2015-16

Bench: Shri Ss Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.1692, 1693, 1694 & 1695 / Chny/2025 Assessment Years-2013-14, 2014-15, 2015-16 & 2016-17 Deputy Commissioner Of Income Tax, Loocust Incorp, No.28A, Mgr Nagar, 14Th Street, Circle-1(1) Tirupur. Pn Road, Tirupur, Tamil Nadu-641 602. [Pan: Aabfl6721C] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपील सं./Co Nos.-77, 78, 79 & 80 / Chny/2025, Assessment Years-2013-14, 2014-15, 2015-16 & 2016-17 Loocust Incorp, Deputy Commissioner Of Income Tax, No.28A, Mgr Nagar, 14Th Street, Circle-1(1) Pn Road, Tirupur, Tirupur. Tamil Nadu-641 602. [Pan: Aabfl6721C] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By : Mr.T.Banusekar, Advocate प्रत्यर्थी की ओर से /Revenue By : Mr.Shiva Srinivas, Cit सुनवाई की तारीख/Date Of Hearing : 08.10.2025 घोषणा की तारीख /Date Of Pronouncement : 02.12.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

For Appellant: Mr.T.Banusekar, AdvocateFor Respondent: Mr.Shiva Srinivas, CIT
Section 132Section 143(3)

80/Chny/2025 a) As the very issue of notice u/s. 148 was based ONLY on the information from the JCIT(OSD), Mumbai, It amounted to borrowed satisfaction, exhibiting non- application of mind. b) As notice u/s. 148 dt. 30/03/2021 is not valid in so far as the date of service ... Income Tax for reopening the assessment is without application of mind. 3. For that the assessment was reopened only on the basis of borrowed satisfaction and therefore the reopening was without application of mine. Addition of Rs.2,39,90,590/- being purported bogus purchases 1. For that the Assessing Officer

Deputy Commmissioner of Income Tax, Circle-1, Tirupur vs. Loocust Incorp, Tirupur

In the result, appeal of the assessee vide CO Nos

ITA 1693/CHNY/2025[2014-15]Status: DisposedITAT Chennai02 Dec 2025AY 2014-15

Bench: Shri Ss Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.1692, 1693, 1694 & 1695 / Chny/2025 Assessment Years-2013-14, 2014-15, 2015-16 & 2016-17 Deputy Commissioner Of Income Tax, Loocust Incorp, No.28A, Mgr Nagar, 14Th Street, Circle-1(1) Tirupur. Pn Road, Tirupur, Tamil Nadu-641 602. [Pan: Aabfl6721C] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपील सं./Co Nos.-77, 78, 79 & 80 / Chny/2025, Assessment Years-2013-14, 2014-15, 2015-16 & 2016-17 Loocust Incorp, Deputy Commissioner Of Income Tax, No.28A, Mgr Nagar, 14Th Street, Circle-1(1) Pn Road, Tirupur, Tirupur. Tamil Nadu-641 602. [Pan: Aabfl6721C] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By : Mr.T.Banusekar, Advocate प्रत्यर्थी की ओर से /Revenue By : Mr.Shiva Srinivas, Cit सुनवाई की तारीख/Date Of Hearing : 08.10.2025 घोषणा की तारीख /Date Of Pronouncement : 02.12.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

For Appellant: Mr.T.Banusekar, AdvocateFor Respondent: Mr.Shiva Srinivas, CIT
Section 132Section 143(3)

80/Chny/2025 a) As the very issue of notice u/s. 148 was based ONLY on the information from the JCIT(OSD), Mumbai, It amounted to borrowed satisfaction, exhibiting non- application of mind. b) As notice u/s. 148 dt. 30/03/2021 is not valid in so far as the date of service ... Income Tax for reopening the assessment is without application of mind. 3. For that the assessment was reopened only on the basis of borrowed satisfaction and therefore the reopening was without application of mine. Addition of Rs.2,39,90,590/- being purported bogus purchases 1. For that the Assessing Officer

Deputy Commissioner of Income Tax, Circle-1, Tirupur vs. Loocust Incorp, Tirupur

In the result, appeal of the assessee vide CO Nos

ITA 1692/CHNY/2025[2013]Status: DisposedITAT Chennai02 Dec 2025

Bench: Shri Ss Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.1692, 1693, 1694 & 1695 / Chny/2025 Assessment Years-2013-14, 2014-15, 2015-16 & 2016-17 Deputy Commissioner Of Income Tax, Loocust Incorp, No.28A, Mgr Nagar, 14Th Street, Circle-1(1) Tirupur. Pn Road, Tirupur, Tamil Nadu-641 602. [Pan: Aabfl6721C] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपील सं./Co Nos.-77, 78, 79 & 80 / Chny/2025, Assessment Years-2013-14, 2014-15, 2015-16 & 2016-17 Loocust Incorp, Deputy Commissioner Of Income Tax, No.28A, Mgr Nagar, 14Th Street, Circle-1(1) Pn Road, Tirupur, Tirupur. Tamil Nadu-641 602. [Pan: Aabfl6721C] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By : Mr.T.Banusekar, Advocate प्रत्यर्थी की ओर से /Revenue By : Mr.Shiva Srinivas, Cit सुनवाई की तारीख/Date Of Hearing : 08.10.2025 घोषणा की तारीख /Date Of Pronouncement : 02.12.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

For Appellant: Mr.T.Banusekar, AdvocateFor Respondent: Mr.Shiva Srinivas, CIT
Section 132Section 143(3)

80/Chny/2025 a) As the very issue of notice u/s. 148 was based ONLY on the information from the JCIT(OSD), Mumbai, It amounted to borrowed satisfaction, exhibiting non- application of mind. b) As notice u/s. 148 dt. 30/03/2021 is not valid in so far as the date of service ... Income Tax for reopening the assessment is without application of mind. 3. For that the assessment was reopened only on the basis of borrowed satisfaction and therefore the reopening was without application of mine. Addition of Rs.2,39,90,590/- being purported bogus purchases 1. For that the Assessing Officer

Piyush Sharma, Mumbai vs. Income Tax Officer Ward 20(2)(1), Mumbai

In the result, appeal of the Revenue is partly allowed for statistical purpose

ITA 6256/MUM/2025[2016-17]Status: DisposedITAT Mumbai02 Dec 2025AY 2016-17

Bench: Shri Vikram Singh Yadav & Shri. Raj Kumar Chauhanpiyush Sharma Vs. Ito Ward-20(2)(1) A-1 Apartment, 8Th Floor, Flat No. 87, Piramal Chamber, Lalbaug, Malabar Hills, Mumbai-400 006 Mumbai-400 012 Pan: Aapps2589H (Appellant) (Respondent)

Section 132Section 142(1)Section 144Section 148Section 148ASection 250Section 69

making any independent inquiry or investigation thereof and it was Piyush Sharma issued without application of mind and the AO has merely acted upon borrowed satisfaction, hence the reassessment order framed by the AO is bad in law, illegal and without jurisdiction. The AO with notice u/s 148A(b) provided

Urvashi Girishbhai Lal, Rajkot vs. ITO WD 1(2)(1), Rajkot

In the result, appeal filed by the assessee, is allowed

ITA 466/RJT/2025[2013-14]Status: DisposedITAT Rajkot01 Dec 2025AY 2013-14

Bench: Dr. Arjun Lal Saini

For Appellant: Shri Kalpesh Doshi, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 142(1)Section 143(2)Section 144BSection 147Section 148Section 234ASection 250Section 271(1)(c)Section 68

Urvashi Girishbhai Lal, the information of reopening to the assessee. Apart from these reasons were recorded by the Assessing Officer on borrowed satisfaction without application of mind. Hence, I quash the reassessment proceedings and allow the appeal of the assessee.As the reassessment itself is quashed, all other issues on merits

Mrs. Archana Anil Chechani, Jalna vs. ACIT Central Circle-1, Aurangabad

In the result, the appeal of the assessee is dismissed

ITA 1203/PUN/2024[2012-13]Status: DisposedITAT Pune28 Nov 2025AY 2012-13

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: N O N EFor Respondent: Shri Amol Khairnar
Section 132Section 142(1)Section 144Section 147Section 148Section 254Section 68

opening assessment u/s 147 by issuing notice u/s 148 of the IT. Act, 1961. The learned Assessing Officer proceeded merely on basis of borrowed satisfaction and he has no factual information in his hand to have reason to believe that income has escaped assessment. Thus, the assessment order passed

Malkiat Singh Dhaliwal, Ferozepur City vs. ITO, Ferozepur Cantt

In the result, the appeal of the assessee is allowed

ITA 239/ASR/2025[2012-13]Status: DisposedITAT Amritsar27 Nov 2025AY 2012-13

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta(Hybrid Hearing) I.T.A. No. 239/Asr/2025 Assessment Year: 2012-13 Malkiat Singh Dhaliwal S/O Vs. Ito, Joginder Singh 37, Dashmesh Ferozepur. Nagar, Near Baghi Hospital Ferozepur City Punjab. [Pan:-Aalpd0965E] (Respondent) (Appellant) Appellant By None (Adjournment Application) Sh. Charan Dass, Sr. Dr Respondent By Date Of Hearing 12.11.2025 Date Of Pronouncement 27.11.2025

Section 143(3)Section 148

vide notice u/s 148 dated I.T.A. No. 239/Asr/2025 2 Assessment Year: 2012-13 28/03/2019, has been challenged on account of recording of reasons on borrowed satisfaction of investigation wing and on merits the dispute revolves around an addition of Rs. 2,22,000/- ( Rs. Two lakhs twenty two thousand ) , being

Gireesh Chandra, Etah vs. Income-Tax Officer, Ward 3(1), Etah

In the result, assessee’s appeal is allowed for statistical purposes

ITA 264/AGR/2025[2011-2012]Status: DisposedITAT Agra26 Nov 2025AY 2011-2012

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singhassessment Year: 2011-12

Section 143(2)Section 147Section 148Section 234ASection 250Section 54F

facts to uphold the impugned order passed by the learned Assessing Officer even when the assessing officer acted on 2 | P a g e borrowed satisfaction after relying on the mechanical information without verifying the same. 4. That the learned Commissioner of Income-tax (NFAC) has erred