“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

Manohar Manak Alloys Private Limited, Grant Road East, Mumbai vs. Central Circle 3(2), Mumbai, Nariman Point

ITA 55/MUM/2025[2013-14]Status: DisposedITAT Mumbai11 Sept 2025AY 2013-14

Bench: Smt. Beena Pillai, Jm & Shri Arun Khodpia, Am

For Appellant: Shri Rajkumar Singh (VirtuallyFor Respondent: Shri Annavarn Kasuri, SR. AR

Section 131Section 143(2)Section 143(3)Section 147Section 148Section 250

reassessment proceeding initiated under section 147 of the Income Tax Act, 1961 by the Id. Assessing Officer merely on change of opinion and borrowed satisfaction to reopen the already concluded assessment earlier u/s.143(3) of the Act thus, appellant prays that impugned reassessment proceeding initiated by issue of notice u/s.148 ... assessment also, ld. AR submitted that the facts were not properly appreciated by the ld. CIT(A) as the reopening was totally based on borrowed satisfaction and change of opinion. ITA No. 54/Mum/2025 & Ors. (A.Y. 2012-13 to 2017-18) Manohar Manak Alloys Pvt. Ltd. 11. Per contra, ld. Senior

Manohar Manak Alloys Private Limited, Grant Road East, Mumbai vs. Central Circle 3(2), Mumbai, Nariman Point

ITA 54/MUM/2025[2012-13]Status: DisposedITAT Mumbai11 Sept 2025AY 2012-13

Bench: Smt. Beena Pillai, Jm & Shri Arun Khodpia, Am

For Appellant: Shri Rajkumar Singh (VirtuallyFor Respondent: Shri Annavarn Kasuri, SR. AR

Section 131Section 143(2)Section 143(3)Section 147Section 148Section 250

Anusha Finvest Pvt Ltd, Jaipur vs. Assistant Commissioner of Income Tax Circle 1, Jaipur

In the result, the appeal of the assessee is allowed

ITA 985/JPR/2024[2010-2011]Status: DisposedITAT Jaipur10 Sept 2025AY 2010-2011

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Sh. Saurav Harsh, AdvFor Respondent: Sh. Gautam Singh Choudhary, JCIT

Section 142(1)Section 143(1)Section 143(2)Section 147Section 148

notice u/s. 148 of the Act has been issued mechanically without application of mind and the satisfaction by the Assessing Officer is only the borrowed satisfaction of the Investigation Wing. The Assessing Officer, without applying his mind, has simply on the basis of information of the Investigation Wing jumped ... wrongly upheld the order of the Ld. CIT(A) without appreciating that the reasons in this case are based on borrowed satisfaction and without independent application of mind. Lastly, he submitted that exactly similar issue has already been adjudicated and decided in favour of the assessee by the ITAT, Delhi

Modern Insulators Limited, Abu Road vs. ITO(Tj)O-O the Pr. CIT-2, Jaipur

In the result, the appeal of the assessee is allowed

ITA 784/JPR/2024[2010-11]Status: DisposedITAT Jaipur10 Sept 2025AY 2010-11

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyalmodern Insulators Limited, A-4, Vijay Path, Tilak Nagar, Jaipur 302 004 Pan No.: Aabcm 0860G ...... Appellant Vs.

For Appellant: Mr. Rajiv Sogani, CA, Ld. ARFor Respondent: Mr. Gaurav Awasthy, JCIT, Ld. DR

Section 143Section 143(3)Section 147Section 148Section 250

case of Gemini Leather Stores (supra). 7. Ld. AR also submitted that the reopening has been done without application of mind and on borrowed satisfaction based merely on the information received from investigation wing Kolkata. He drew our attention to Question No. 11 of Praveen Agarwal’s statements ... accommodation entry admitted by Shri Praveen Agarwal i.e. the period 01.04.2005 to 31.03.2008. Essentially, the assessment has been reopened on the basis of borrowed satisfaction of the Investigation Wing 8 Modern Insulators Limited without his own independent application of mind and thus consequential action and proceedings under section

Akhilesh Singh Bhadauria, Delhi vs. ITO, Ward-58(2), Delhi

The appeal is allowed

ITA 2349/DEL/2024[2010-11]Status: DisposedITAT Delhi10 Sept 2025AY 2010-11

Bench: Shri Anubhav Sharma & Shri Manish Agarwalassessment Year: 2010-11 Akhilesh Singh Bhadauria, Vs Ito, A-19, Ground Floor, Ward-58(2), Ghazipur Village, Delhi. Delhi – 110 096 Pan: Altpb9329H (Appellant) (Respondent) Assessee By : Shri Amit Kumar Gupta, Advocate Revenue By : Shri Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing : 14.08.2025 Date Of Pronouncement : 10.09.2025

For Appellant: Shri Amit Kumar Gupta, AdvocateFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR

Section 144Section 147Section 234BSection 271(1)(c)Section 282Section 69A

upholding the order of the assessing officer which was passed on the basis of reasons to believe which were erroneous and were based on borrowed satisfaction. 6) The learned Commissioner of Income-tax (Appeals) erred in upholding the order of the Assessing Officer in confirming the addition

Deputy Commissioner of Income Tax, Central Circle 3(2), Kolkata, Aayakar Bhawan Poorva vs. Bhagwan Das Agarwal, Kolkata

In the result, appeal of the revenue is dismissed

ITA 1254/KOL/2025[2014-15]Status: DisposedITAT Kolkata09 Sept 2025AY 2014-15

Bench: Shri George Mathan & Shri Rakesh Mishraआयकर अपील सं/Ita No.1254/Pat/2025 (निर्धारण वर्ा / Assessment Year : 2014-2015) Dcit, Central Circle-3(2), Vs Bhagwan Das Agarwal, Kolkata 21, Hemant Basu Sarani, Dalhousie, Kolkata-700001 Pan No. :Afjpa 9084 Q (अपीलधर्थी /Appellant) (प्रत्यर्थी / Respondent) .. रधजस्व की ओर से /Revenue By : Shri Raja Sengupta, Cit-Dr निर्धाररती की ओर से /Assessee By : Shri Devesh Poddar, Advocate सुनवाई की तारीख / Date Of Hearing : 09/09/2025 घोषणा की तारीख/Date Of Pronouncement : 09/09/2025 आदेश / O R D E R Per George Mathan, Jm: This Is An Appeal Filed By The Revenue Against The Order Passed By The Ld.Cit(A), National Faceless Appeal Centre (Nfac), Delhi, Dated 24.03.2025 For The Assessment Year 2014-2015. 2. Shri Raja Sengupta, Ld. Cit-Dr Appeared On Behalf Of The Revenue & Shri Devesh Poddar, Ld. Ar Appeared On Behalf Of The Revenue. 3. A Perusal Of The Facts Of The Present Case Shows That The Order Of The Ld. Cit(A) Dated 24.03.2025 Has Been Received In The Office Of Pr.Cit, Central-2, Kolkata On 24.03.2025. The Limitation For Filing The Appeal Expired On 23.05.2025 & The Appeal Has Been Filed On 09.06.2025. Thus, There Is A Delay Of 21 Days In Filing The Appeal By The Revenue. In This Regard, The Revenue Has Filed A Condonation Application Stating Therein As Under :-

For Appellant: Shri Devesh Poddar, AdvocateFor Respondent: Shri Raja Sengupta, CIT-DR

Section 153ASection 3Section 68

fact that there is no application of mind by the Assessing Officer and the satisfaction appears to be more akin to a ‘borrowed satisfaction’ without any live link to the facts of the case. The relevant findings of the ld. CIT(A) recorded in this regard are as under :- Applying ... fact and conclusion thereof. There is no application of mind in any manner and his satisfaction appears to be more akin to a 'borrowed satisfaction' without any live link to the facts of the case. 11. A perusal of the grounds raised by the revenue clearly shows that the revenue

Narayan Suppliers Pvt. Ltd., Kolkata vs. I.T.O., Ward - 6(3), Kolkata

In the result, appeal of the assessee is dismissed

ITA 1077/KOL/2024[2011-2012]Status: DisposedITAT Kolkata08 Sept 2025AY 2011-2012

Bench: Shri George Mathan & Shri Rakesh Mishra

For Appellant: Shri Avijit Ghoshal, ARFor Respondent: Shri Raja Sengputa, CIT-DR

Section 10(38)

opening the assessment on the basis of vague information and vague reasons without any tangible material or independent application of mind but on borrowed satisfaction, suspicion and surmises which is not correct as well as untenable in law. For this ground, it is submitted that the case of the assessee ... conclusions of AO one after the other which were at best a reproduction of the conclusion in the investigation report and indeed a I borrowed satisfaction". Delhi High Court in the case of Pr. CIT -VS- RMG Polyvinyl (1) Ltd., (2017) 396 ITR 5 (Del.) in which it was held

Assistant Commissioner of Income Tax, Nungambakkam vs. Pawan Cargo Forwards Pvt Ltd, Chennai

In the result, appeal filed by the revenue is dismissed in terms above and cross objection filed by the assessee become infructuous in terms of our above order

ITA 3116/CHNY/2024[2013-14]Status: DisposedITAT Chennai08 Sept 2025AY 2013-14

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri S. R. Raghunathaआयकरअपील सं./ Ita No.3116/Chny/2024 (िनधा&रणवष& / Assessment Year: 2013-14) The Asst. Commissioner Of Income Pawan Cargo Forwards Pvt. Ltd., Tax, Vs. 518, Mkn Road, Pawan Imperia, Circle-1(Ltu) Alandur Mkn Road, Chennai. Chennai – 600 016. [Pan: Aaccp 2477P] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Respondent: 26.06.2025

Section 148Section 148ASection 151

course of the survey action. 6. The Learned Commissioner of Income-tax (Appeal) erred in holding that the reassessment order is based on borrowed satisfaction and failed to note the Assessing officer's finding that the share price of the scrip had been rigged from Rs.2 per share to Rs.90

Laurels Properties Private Limited, Delhi vs. DCIT CC-1(4), Mumbai

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

ITA 1179/MUM/2025[2015-16]Status: DisposedITAT Mumbai05 Sept 2025AY 2015-16

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 143(3)Section 250

Income Tax (Appeals) erred in not treating the re-opening of assessment as bad-in-law since the re-opening was entirely based on borrowed satisfaction and without application of mind or independent enquiries on the part of the Ld. Assessing Officer. 3. On the facts and in the circumstances ... consequently the order of the assessment was illegal, bad in law and without jurisdiction. It was submitted that the reopening was entirely based on borrowed satisfaction and without application of mind or independent enquiries on the part of the AO. It was further argued that the assessment was re-opened

Zalavadiya Kalubhai Mohanbhai, HUF, Ahmedabad vs. The Income Tax Officer, Ward-5(3)(1), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 806/AHD/2024[2015-16]Status: DisposedITAT Ahmedabad04 Sept 2025AY 2015-16

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha, Accountannt Member Assessment Year 2015-16

For Appellant: Shri Tushar Hemani, Sr. A.R. &For Respondent: Shri Abhijit, Sr. D.R

Section 10(38)Section 142(1)Section 143(2)Section 147Section 148

without application of mind. The ld CIT(A)-NFAC has disposed-off of this ground without considering appellant's submission. The notice issued on borrowed satisfaction is legal and void and consequently assessment based on such notice may kindly be quashed. 3. Ground No. 3-Assessment

Ms Aditya Plastic, Rajkot vs. The Income Tax Officer, NFAC, Delhi

In the result, the appeal of the assessee is allowed

ITA 186/RJT/2024[2013-14]Status: DisposedITAT Rajkot03 Sept 2025AY 2013-14

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./I.T.A. No.185 & 186/Rjt/2024 (िनधा"रणवष" / Assessment Year :2013-14) बनाम/ M/S Aditya Plastic The Income Tax Officer Umiya Industrial Building Ward-3(1)(1) Vs. Near New Nehru Nagar Rajkot -360 001 Main Road, Dhebar Road Rajkot – 360 004 "ायीलेखासं./जीआइआरसं./Pan/Gir No. : Aajfa 4558 In (अपीलाथ"/Appellant) .. (""थ" / Respondent) Assessee By : Shri D.M. Rindani, Ld.Ar Revenue By : Shri Abhimanyu Singh Yadav, Ld.Sr.Dr सुनवाईकीतारीख/ Date Of Hearing 05/06/2025 घोषणाकीतारीख/Date Of Pronouncement 03/09/2025 आदेश / O R D E R Per Bench-: Captioned Two Appeals Filed By The Same Assessee Pertaining To Assessment Year (Ay) 2013-14 Are Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Cit(A)-[(In Short “Ld.Cit(A)”] Vide Order Dated 01/02/2024, Which In Turn Arises Out Of An Assessment Order Dated 29/09/2021Passed By The Assessing Officer (Ao) U/S. 147 R.W.S. 144 Of The Income Tax Act, 1961 (In Short, “The Act”) Pertaining To Assessment Year (Ay) 2013-14. 2. The Grounds Of Appeal Raised By The Assessee Are As Follows:

For Appellant: Shri D.M. Rindani, Ld.ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld.Sr.DR

Section 119Section 142(1)Section 147Section 148Section 69A

Counsel for the assessee also submitted that the reasons submitted by the AO are bad in law and there are basis on the borrowed satisfaction and there was no material before the AO to re-open the assessment proceedings. The Ld. Counsel for the assessee also submitted before us that ... further enquiries and has not applied his mind while forming a belief that income had escaped assessment in case of Appellant. This amounts to borrowed satisfaction which is not permitted in law. Narsimha Trading Co. (2025) 170 taxmann.com 10 (Guj HC). 5.Reasons recorded for re-opening do not show

Ms Aditya Plastic, Rajkot vs. The Income Tax Officer, Ward 3(1)(1), Rajkot-

In the result, the appeal of the assessee is allowed

ITA 185/RJT/2024[2013-14]Status: DisposedITAT Rajkot03 Sept 2025AY 2013-14

For Appellant: Shri D.M. Rindani, Ld.ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld.Sr.DR

Section 119Section 142(1)Section 147Section 148Section 69A

Aviral Marketing Pvt. Ltd., Kolkata vs. DCIT, Circle 4(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1423/KOL/2025[2012-2013]Status: DisposedITAT Kolkata03 Sept 2025AY 2012-2013

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2012-13 Aviral Marketing Pvt. Ltd…….……………..............................……….……Appellant 7, Camac Street, Azimganj House, 1St Floor, Shakespeare Sarani, Kol- 700017. [Pan: Aacca3794N] Vs. Dcit, Circle-4(1), Kolkata……………………………….....……...…..…..Respondent Appearances By: Shri Manoj Kataruka, Advocate, Appeared On Behalf Of The Appellant. Shri Ruchika Sharma, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : September 02, 2025 Date Of Pronouncing The Order : September 03, 2025 Order Per Rajesh Kumar: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 07.11.2024 Of The National Faceless Appeal Centre [Hereinafter Referred To As The “Ld. Cit(A)”] Passed U/S 250 Of The Income Tax Act, 1961 [Hereinafter Referred To As The “Act”].

Section 143(3)Section 147Section 148Section 250Section 68

ambiguous and reopening based on the said reasons may be quashed. Besides, the ld. counsel argued that the Assessing Officer has acted as borrowed satisfaction of the investigation wing and has not recorded his own satisfaction. In defence of his argument, the ld. counsel has relied on the decision ... that the conclusions of the Assessing Officer are at best a reproduction of the conclusion in the investigation report and indeed it is a borrowed satisfaction as the reasons fail to demonstrate the link between the tangible material and the formation of the reasons to believe that income has escaped

Star Ceramics, Chitradurga vs. Income Tax Officer, Ward-1, Chitradurga

In the result, the appeal of the assessee is allowed

ITA 1064/BANG/2025[2016-17]Status: DisposedITAT Bangalore03 Sept 2025AY 2016-17

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year : 2016-17

For Appellant: Ms. Richa Bakiwala & Shri Hemasundar Rao P., CAsFor Respondent: Shri Thamba Mahendra, CIT(DR)(ITAT), Bengaluru

Section 147Section 148Section 148ASection 68Section 69A

same stating that the transactions are genuine. The assessee also objected to the reopening of assessment stating that reopening has been made on the borrowed satisfaction. The ld. CIT(A) dismissed the grounds on reopening and further with respect to the addition of Rs.50 lakhs and Rs.12

Gupta Builders and Developers, Mumbai vs. Asst. Commissioner of Income Tax Central Circle 4(3), Mumbai

Appeal of the assessee is allowed

ITA 4361/MUM/2025[2015-16]Status: DisposedITAT Mumbai03 Sept 2025AY 2015-16

Bench: Shri Saktijit Dey, Vp & Ms Padmavathy S, Am

For Appellant: Ms. Ritika Agarwal, Advocate

Section 133ASection 143(1)Section 148Section 148ASection 151Section 250Section 68

bringing on record any tangible material. 4. BECAUSE the CIT(A) has erred upholding that the reopening of the assessment was not based on "borrowed satisfaction," despite the fact that the AO has merely relied on the information provided by the survey party without conducting any independent verification, applying

Naresh Kumar Jain (HUF), Delhi vs. DCIT Central Circle-26, Delhi

In the result, both the appeals of the assessee in ITA Nos

ITA 1575/DEL/2025[2017-18]Status: DisposedITAT Delhi03 Sept 2025AY 2017-18

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Ms. Shilpi Sawaria, AdvFor Respondent: Shri Manish Gupta, Sr. DR

Section 147Section 151Section 153CSection 68Section 69C

without approval of the competent authority as required u/s 151 of the Act which is bad in the eyes of law and based on borrowed satisfaction. It was, therefore, prayed that the ld. CIT(A) be declared as bad in law. 6. Per contra, the ld. DR relied upon

Naresh Kumar Jain (HUF), Delhi vs. DCIT Central Circle-26, Delhi

In the result, both the appeals of the assessee in ITA Nos

ITA 1574/DEL/2025[2016-17]Status: DisposedITAT Delhi03 Sept 2025AY 2016-17

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Ms. Shilpi Sawaria, AdvFor Respondent: Shri Manish Gupta, Sr. DR

Section 147Section 151Section 153CSection 68Section 69C

Aakash Developers, Thane vs. ACIT, Circle 1, Thane

In the result the appeal filed by the assessee stands allowed

ITA 1767/MUM/2025[2010-11]Status: DisposedITAT Mumbai29 Aug 2025AY 2010-11

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

Section 132(4)Section 143(3)Section 147Section 148

carried out by the Ld.AO, neither before issuance of notice u/s.148 nor during the assessment proceedings. The Ld.AR thus emphasised that, based on borrowed satisfaction reopening of the assessment was done in the case of assessee for the year under consideration. 4.1 The Ld.AR submitted that, statements of the member

Asst. Commissioner of Income Tax, Vikash Bhwan Delhi vs. Sumit Chhabra, Delhi

The appeal of the assessee is allowed and appeal of the Revenue is dismissed as infructuous

ITA 3879/DEL/2024[2018-19]Status: DisposedITAT Delhi29 Aug 2025AY 2018-19

Bench: Ms. Madhumita Roy & Shri Naveen Chandrasumit Chhabra Vs. Assessment Unit, Nafac, Hno. 3, Kiran Vihar, Vikas Bhawan Karkardooma,, Anand Delhi Vihar, S.O. Anand Vihar East Delhi – 110092 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aecpc8652G Appellant .. Respondent Acit, Vikash Bhawan Vs. Sumit Chhabra Room No. 216, 2Nd Floor, H. No. 3, Kiran Vihar, D Block, Vikash Bhawan, Karkardooma, I.P. Estate, Delhi Delhi – 110092 110002 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aecpc8652G Appellant .. Respondent

For Appellant: Sh. Gaurav Jain, AdvFor Respondent: Sh. Manish Gupta, Sr. DR

Section 139(1)Section 147Section 148ASection 69C

submissions made by the Ld. Counsel appearing for the assessee before us that the issuance of notice under Section 148A(b) is based on borrowed satisfaction on the information received in accordance with risk management strategy that the assessee has made bogus purchases without making any further inquiries suggesting that ... conducted by him, we find the reason to believe drawn solely on the basis of the DDIT Investigation Wing report is nothing but a borrowed satisfaction which renders the proceeding under Section 147/148 of the Act vitiated and the proceeding is, therefore, quashed

Sumit Chhabra, Kiran Vihar, East Delhi vs. Assessment Unit, Nafac, Vikas Bhawan Delhi

The appeal of the assessee is allowed and appeal of the Revenue is dismissed as infructuous

ITA 3556/DEL/2024[2018-19]Status: DisposedITAT Delhi29 Aug 2025AY 2018-19

For Appellant: Sh. Gaurav Jain, AdvFor Respondent: Sh. Manish Gupta, Sr. DR

Section 139(1)Section 147Section 148ASection 69C