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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

Morpheus Developers Private Limited, Delhi vs. Pr, CIT Delhi-4, Delhi

Appeal is allowed

ITA 1753/DEL/2023[2016-17]Status: DisposedITAT Delhi20 Aug 2025AY 2016-17

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaassessment Year: 2016-17 Morpheus Developers Private Vs Pr. Cit, Ltd., Delhi-4, 1, Main Road, Delhi. Maujpur, Delhi – 110 053. Pan: Aaicm1972A (Appellant) (Respondent) Assessee By : Shri Yudhister Mehtani, Ca Revenue By : Ms Amisha S. Gupt, Cit-Dr Date Of Hearing : 05.08.2025 Date Of Pronouncement : 20.08.2025 Order Per Anubhav Sharma, Jm: This Appeal Is Preferred By The Assessee Against The Order Dated 18.03.2021 Of The Principal Commissioner Of Income-Tax (Hereinafter Referred To As The Ld. Pciit) U/S 263 Of The Income Tax Act, 1961 (Hereinafter Referred As ‘The Act’) In Revision No.Pcit, Delhi-4/Revision-263/100000183556/2021 Arising Out Of The Order Dated 29.12.2018 Passed U/S 143(3) Of The Act By The Ito, Ward-17(1), Delhi (Hereinafter Referred To As The Ld. Ao). 2. At The Outset, The Ld. Ar Has Pointed Out That There Was A Delay In Filing The Appeal. On Hearing On The Application For Condonation Of Delay, We Find That Primarily For The Reason That There Were Some Issues Pending Before The National Company Law Tribunal Followed By Appeal, There Could Not Be Adequate Representation Of The Assessee. In Fact, In January, 2023, The Greater Noida Authority Had Cancelled The Plot On Which The Company Was Running The Project. Thus, We Are Of The Considered View That The Delay Although Of Substantial Period Of Around 746 Days, Deserves To Be Condoned.

For Appellant: Shri Yudhister Mehtani, CAFor Respondent: Ms Amisha S. Gupt, CIT-DR
Section 143(3)Section 263

manner merely accepting the proposal of the AO. The ld. DR has opposed the same and submitted that it is not a case of borrowed satisfaction and merely on the basis of reproduction of some part of the letter of the AO, it cannot be called a mechanical exercise ... Additional CIT, which fact is also mentioned in para 2 of the order of learned Pr. CIT. Hence, it is a clear case of borrowed satisfaction by the learned Pr. CIT, which is in complete violation of provisions of Section 263 of the Act. In the case before

Raj International Limited, Mumbai vs. Deputy Commissioner of Income Tax, Circle-4(3)(1), Mumbai

ITA 6286/MUM/2024[2014-15]Status: DisposedITAT Mumbai18 Aug 2025AY 2014-15

Bench: Shri Pawan Singh, Jm & Ms Padmavathy S, Am

For Appellant: Shri K. Gopal Adv. & Ms. Neha
Section 143(3)Section 147Section 148Section 151ASection 250Section 69A

learned CIT(A) erred in confirming the reopening based on reasons recorded by the learned A.O which are vague and based on borrowed satisfaction, without having done any further enquiry or placing on record any material / evidences gathered during the course of proceedings. 2. Under the facts ... conducted any private / independent enquiry. The learned A.O has merely relied on borrowed satisfaction. 5. Under the facts and in law, the learned CIT(A) erred in confirming addition of Rs. 6,67,32,700/- being amount of secured loan outstanding, considering the same as income. 5.1 Under the facts

Raj International Limited, Mumbai vs. Deputy Commissioner of Income Tax, Circle-4(3)(1), Mumbai

ITA 6285/MUM/2024[2013-14]Status: DisposedITAT Mumbai18 Aug 2025AY 2013-14

Bench: Shri Pawan Singh, Jm & Ms Padmavathy S, Am

For Appellant: Shri K. Gopal Adv. & Ms. Neha
Section 143(3)Section 147Section 148Section 151ASection 250Section 69A

learned CIT(A) erred in confirming the reopening based on reasons recorded by the learned A.O which are vague and based on borrowed satisfaction, without having done any further enquiry or placing on record any material / evidences gathered during the course of proceedings. 2. Under the facts ... conducted any private / independent enquiry. The learned A.O has merely relied on borrowed satisfaction. 5. Under the facts and in law, the learned CIT(A) erred in confirming addition of Rs. 6,67,32,700/- being amount of secured loan outstanding, considering the same as income. 5.1 Under the facts

M/S Ashoka Portfolio Management Pvt. Ltd., Jaipur vs. ITO, Ward-1(1), Jaipur

In the result, appeal of the Assessee is allowed as per the

ITA 690/JPR/2025[2008-09]Status: DisposedITAT Jaipur14 Aug 2025AY 2008-09

Bench: Dr. Manish Borad

For Appellant: Shri P.C. Parwal, CAFor Respondent: Shri Gautam Singh Choudhary
Section 132Section 139(1)Section 143(1)Section 143(3)Section 147Section 148Section 250Section 68

solely on the basis of information received from Investigation Wing, Bombay and without conducting any further enquiry and Ld.AO based on the borrowed satisfaction has issued notice u/s. 148 of the Act. It is submitted that the reason for reopening was that the income ... that Ld.AO has issued notice u/s. 148 of the Act merely on the ITA.No.690/JPR/2025 (M/s. Ashoka Portfolio Management Pvt. Ltd.) basis of borrowed satisfaction and has not conducted any independent enquiry. I have perused the records and observe tha assessee is a private limited company and return

Viramgam Mahesana Projects Ltd., New Delhi vs. ACIT, New Delhi

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

ITA 119/DEL/2015[2006-07]Status: DisposedITAT Delhi14 Aug 2025AY 2006-07

Bench: Shris.Rifaur Rahman & Shri Vimal Kumarviramgam Mahesana Project Limited, Vs. Acit, Circle 17(1), E – 9, 3Rd Floor, New Delhi. Ndse Part 2, New Delhi – 110 049. (Pan :Aabcv7027L) (Appellant) (Respondent) Assessee By : Shri K. Sampath, Advocate Shri V. Raja Kumar, Advocate Revenue By : Shri Dayainder Singh Sidhu, Citdr Date Of Hearing : 03.06.2025 Date Of Order : 14.08.2025 Order Per S.Rifaur Rahman: 1. Thisappeal Is Filed By The Assesseeagainst The Order Of Ld. Commissioner Of Income-Tax (Appeals)-19, New Delhi [Hereinafter Referred To As ‘Ld. Cit (A)]Dated 22.10.2014For Assessment Year 2006-07 Raising Following Grounds Of Appeal :- “1 That On The Facts & Circumstances Of The Case & In Law, The Ld. Cit(A) Has Erred In Confirming The Initiation Of The Reassessment Proceedings, U/S 148 Of The Income Tax Act & Also Failed To Appreciate That Neither The Mandatory Requirements Of Section 148 Of The Income Tax Act Nor The Pre-Conditions For Invoking The Provisions

For Appellant: Shri K. Sampath, AdvocateFor Respondent: Shri Dayainder Singh Sidhu, CITDR
Section 143(3)Section 147Section 148Section 234

Indian Railways itself. The assessment has thus been re-opened without any examination or application of mind and is based wholly on a borrowed satisfaction and being so is unsustainable in law, particularly in view of the judgement of Delhi High Court Tansworld International Inc. vs. JCIT ... para 24). 5 Any satisfaction recorded u/s 147 of the Act on the basis of a borrowed satisfaction is untenable in law. Authorities on this point are the jurisdictional High Court decisions in – a. Pro CIT vs. Meenakshi Overseas P. Ltd. (2017) 395 ITR 677 (Del) b. Sarthak Securities

K & P Enterprises, Bandra Mumbai vs. DCIT 22(1), Piramal Chamber, Mumbai

In the result, the appeal is allowed for statistical

ITA 2263/MUM/2025[2010-11]Status: DisposedITAT Mumbai12 Aug 2025AY 2010-11

Bench: Shri Saktijit Dey & Shri Prabhash Shankar

For Appellant: Shri Bhupendra Shah, ARFor Respondent: Shri Hemanshu Joshi (Sr. DR)
Section 131Section 133(6)Section 143(3)Section 147Section 234ASection 249(2)Section 249(3)Section 271(1)(c)

basis of information received from the DG (Inv), Mumbai who has conducted search operation on Shri Bhanwarlal Jain Group and on the basis of borrowed satisfaction b. merely on the basis of suspicion, surmises and conjectures and without any material on record c. Relying on third party statements and without

Assistant Commissioner of Income Tax, 4(1)(1), Mumbai vs. Haresh Shantichand Jhaveri, Mumbai

In the result, appeal of the Revenue is dismissed

ITA 1971/MUM/2025[2015-16]Status: DisposedITAT Mumbai12 Aug 2025AY 2015-16

Bench: Shri Saktijit Dey & Shri Prabhash Shankarassistant Commissioner Of V/S. Haresh Shantichand Income Tax, Ward – 4(1)(1), बनाम Jhaveri, Room No. 642, Aaykar Bhavan, Ps 6-7 Rotunda Bldg, M.K. Road, Churchgate, Samachar Marg, Mumbai – Mumbai–400 020, Maharashtra 400 023, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aabpj8053B Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Nitin Shantilal Doshi, ARFor Respondent: Shri Hemanshu Joshi (Sr. DR)
Section 147

profit and chose to ignore the loss. The assessee was denied a fair opportunity the rebut allegations effectively. The AO’s approach mere borrowed satisfaction without independent tangible material demonstrative escapement of the income by the appellant. The department has neither produced any document nor any witness statement that directly

Sh. Kapil Taneja, Jaipur vs. The Deputy Commissioner of Income Tax Circle-1, Jaipur

In the result, the appeal of the assessee is allowed

ITA 578/JPR/2025[2017-18]Status: DisposedITAT Jaipur11 Aug 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Tarun Mittal, CAFor Respondent: Sh. Gorav Avasthi, JCIT
Section 144BSection 147Section 148Section 148ASection 151ASection 69A

Reopening solely on the basis of information received from some other officials without recording his own subjective satisfaction and thus same is based on borrowed satisfaction. In this regard, at the outset, information as shared by ld.AO vide notice u/s 148A(b) of the Act (APB 34-38) is again ... mechanical manner, which has been done in the case in hand. Thus, re-opening of the case based on the borrowed satisfaction on the information provided by some other official without carrying out independent verification of the information with reference to return of income and financial affairs of the assessee

Prabhodhankarthakare Vidyalaya, Boisar vs. ITO Exemption Ward, Thane, Quereshi Mansion

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

ITA 4215/MUM/2025[2018-19]Status: DisposedITAT Mumbai11 Aug 2025AY 2018-19

Bench: Shri Narendra Kumar Billaiya, Hon’Ble & Shri Sandeep Singh Karhail, Hon’Ble

For Appellant: Shri Bhupendra Shah, A/RFor Respondent: Mr. Virabhadra S. Mahajan, Sr. D/R
Section 69

learned Assessing Officer erred passing ex-parte order us 144B r.w.s. 147/148A r.w.s 144 a. merely on the basis of borrowed satisfaction, b. relying upon information from Insight Portal c. No asset is found above Rs 50 lac d. By overlooking the fact that this cash deposit of fees

Pushpa Devi, Rishikesh vs. Income Tax Officer, Rishikesh

In the result the Appeal of the Assessee is allowed

ITA 78/DDN/2025[2019-20]Status: DisposedITAT Dehradun08 Aug 2025AY 2019-20

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Pushpa Devi Vs. Income Tax Officer, 31-Awas Vikas Colony, Ward 1(4) (1), Verbhadara Road, Rishikesh, Rishikesh, 249201, Uttarakhand Rishikesh, Uttarakhand Pan: Aldpd9616P Appellant Respondent Assessee By Sh. K. K. Juneja, Adv Revenue By Sh. Amar Pal Singh, Sr. Dr Date Of Hearing 10/07/2025 Date Of Pronouncement 08/08/2025 Order

Section 144Section 144BSection 147Section 28Section 68

grounds of Appeal are as under:- “1. That in facts and circumstances of the case, the initiation of re- opening proceedings relying upon the borrowed satisfaction is illegal and against the jurisdictional pronouncements. 2. That in facts and circumstances of the case, there is no independent satisfaction recorded

Tushar Enterprises, Goregaon East, Mumbai vs. Jurisdictional Assessing Officer, Kautilya Bhavan, Bkc, Bandra East Mumbai

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

ITA 2542/MUM/2024[2011-12]Status: DisposedITAT Mumbai08 Aug 2025AY 2011-12

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhailtushar Enterprises, 2-A/401-402 Dheeraj Valley, Mohan Gokhale Road, Saibaba Complex, Goregaon East, Mumbai ............... Appellant Maharahstra - 400063 Pan : Aaaft1242R V/S Income Tax Officer, ……………… Respondent Ward – 41(4)(4), Kautilya Bhavan, Bkc, Bandra East, Mumbai-400051 Assessee By : Shri Sanjay Shah, Ca Revenue By : Shri Asif Karmali, Sr.Dr

For Appellant: Shri Sanjay Shah, CAFor Respondent: Shri Asif Karmali, Sr.DR
Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 250Section 50C

section 147 of the Act were initiated. It is the plea of the learned AR that the reassessment proceedings were initiated based on the borrowed satisfaction and no independent enquiry was conducted by the AO to come to the aforesaid conclusion. In the present case, it is pertinent to note

Income Tax Officer, Jaipur vs. Pooja Kedia, Jaipuir

In the result, the appeal of the revenue is dismissed

ITA 1321/JPR/2024[2019-20]Status: DisposedITAT Jaipur07 Aug 2025AY 2019-20
For Appellant: Sh. Siddharth Ranka, Adv. &For Respondent: Sh. Gaurav Awasthi, JCIT, Sr. DR
Section 142(1)Section 147Section 148ASection 68

Revenue is hereby dismissed. • Narmada Concast Pvt. Ltd. v. DCIT 2024 (5) TMI 950 dated 03.01.2024 (ITAT Ahmedabad): Validity of reassessment proceedings on borrowed satisfaction allegation of non independent application of mind - As per AO assessee had entered into high value financial transactions facilitating bogus accommodation entries Addition ... with bank entry details and then formulated “his own reason to belief” but simply followed the information given by DGIT, which is nothing but “borrowed satisfaction” and is against the provision of Section 147 of the Act. Therefore the same is liable to be quashed. As decided in Varshaben Sanatbhai

Shri Omkar Nagari Sah Pat Sanstha, Sangli vs. National Faceless Assessment Center, Delhi

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

ITA 1617/PUN/2024[2015-16]Status: DisposedITAT Pune07 Aug 2025AY 2015-16

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1617/Pun/2024 धििाारण वर्ा / Assessment Year: 2015-16 Shri Omkar Nagari Sahpat Nfac, Delhi Sanstha Ltd., Patrakar Nagar, Behind St Vs. Stand, Sangli-416416 Maharashtra Pan-Aabas8331A अपीलार्थी / Appellant प्रत्यर्थी/Respondent Assessee By: Ca Kishor Phadke Department By: Shri Amol Khairnar Cit-Dr Date Of Hearing: 07-08-2025 Date Of Pronouncement: 14-08-2025

For Appellant: CA Kishor PhadkeFor Respondent: Shri Amol Khairnar CIT-DR
Section 147Section 148Section 153CSection 250Section 69A

inquiry was made by Ld. AO and the belief was formed merely on the vague information received. Accordingly, the re-assessment proceedings based on borrowed satisfaction needs to be quashed. The Appellant prays that it be held accordingly. 5. On the facts and under the circumstances

Hasmukhbhai Raghubhai Goriya, Old Dhuva vs. Income Tax Officer, Morbi

In the result, appeal filed by the assessee is allowed

ITA 195/RJT/2025[2011-12]Status: DisposedITAT Rajkot06 Aug 2025AY 2011-12

Bench: Dr. Arjun Lal Saini. आयकर अपील सं./Ita No.195/Rjt/2025 "नधा"रण वष"/Assessment Year: (2011-12) (Hybrid Hearing) Hasmukh Raghubhai Goriya, Vs. Income Tax Officer, Ward 2, Morbi Village: Old Dhuva, Taluka: J.K. Chamber, National High Way-8A, Wakaner, District: Morbi- Near Ravi Residency Hotel, Lalpar, 363622 Morbi-363642 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Awupg 3221 D (Appellant) (Respondent)

For Appellant: Shri Chetan Agarwal, Ld. ARFor Respondent: Shri Dheeraj Kumar Gupta, Ld. Sr. (DR)
Section 133(6)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 250Section 69A

verified by assessing officer and hence there is complete non-application of mind. Hence, the Ld. AO reopened assessee`s case on mere borrowed satisfaction and without verifying details. 13. The reasons must show due application of mind to the information. Assessing officer also cannot reopen assessment merely because

Mukesh Jain HUF, Jaipur vs. DCIT, Jaipur

In the result, the appeal of the assessee is allowed

ITA 620/JPR/2025[2010-11]Status: DisposedITAT Jaipur06 Aug 2025AY 2010-11

Bench: Reopening The Assessment & Without Independent Application Of Mind. Thus, The Action Of The Ld. Ao In Reopening The Assessment U/S 148 & The Consequent Reassessment Order So Passed Deserves To Be Held Bad In Law.

For Appellant: Sh. Tarun Mittal, CAFor Respondent: MS. Alka Gautam, CIT-DR
Section 143(3)Section 147Section 148Section 68

appellant submission is the AO has merely relied upon information from external sources without conducting an independent inquiry. The reopening is based on borrowed satisfaction, which is against the principles laid down in CIT v. S. Goyanka Lime & Chemicals Ltd. (2015) 56 taxmann.com 390 (SC), where the Supreme Court held ... mechanical manner as has been done in the case in hand. The re-opening of the case based on the borrowed satisfaction on the information provided by some other official without in any manner recording his own independent satisfaction deserves to be held illegal. In this regard reliance is placed

Deputy Commissioner of Income Tax, Jaipur vs. Bharat Spun Pipe and Construction Company, Jaipur

In the result the appeal of the revenue in ITA no

ITA 360/JPR/2025[2017-18]Status: DisposedITAT Jaipur06 Aug 2025AY 2017-18
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Ms. Alka Gautam, (CIT) (V.C.)
Section 144BSection 147Section 148Section 148ASection 153C

dated 30.07.2022 issued without DIN 13 ITA No. 360/JPR/2025 & CO No. 19/JPR/2025 Bharat Spun Pipe and Construction Co., Jaipur. 8. Re-opening done on borrowed satisfaction At the outset, as submitted above, it is reiterated that assessment u/s 143(3) of the Act was already completed by Id. AO vide ... application of mind by Id.AO while recording the satisfaction of escapement of income before issue of notice u/s 148 and he simply proceeded on borrowed satisfaction reached by some other officials without verifying the same, therefore, the entire proceedings initiated u/s 147 deserve to be held

Jajoo Rashmi Refractories Limited, Jaipur, Rajasthan vs. DCIT, Circle 4-Jaipur, Jaipur, Rajasthan

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

ITA 209/JPR/2025[2018-19]Status: DisposedITAT Jaipur06 Aug 2025AY 2018-19
For Appellant: Ms. Prabha Rana, AdvocateFor Respondent: Shri Gaurav Awasthi, JCIT-DR
Section 131Section 145Section 147Section 69C

speak for themselves. Your honour, the reasons recorded by the Ld. AO in the present case were based on a 'borrowed satisfaction' and on the directions of the Investigation Wing without any independent application of his own mind. The crucial link between the material and the formation of the belief ... speak for themselves. Your honour, the reasons recorded by the Ld. AO in the present case were based on a 'borrowed satisfaction' and on the directions of the Investigation Wing without any independent application of his own mind. The crucial link between the material and the formation of the belief

Rsd Containers Private Limited, Jaipur vs. ITO, Ward 7(1), Jaipur

In the result, the appeal of the assessee is allowed

ITA 1320/JPR/2024[2017-18]Status: DisposedITAT Jaipur06 Aug 2025AY 2017-18
For Appellant: Shri Mukesh Khandelwal, C.AFor Respondent: Mrs. Anita Rinesh, JCIT, Sr.-DR
Section 115BSection 147Section 148Section 149Section 151Section 151ASection 153CSection 68

notice u/s 148 without application of mind. It has been held by various judicial authorities that no notice u/s 148 can be issued on borrowed satisfaction of another wing or another officer of the department and the AO has to apply his independent mind for reaching on the satisfaction about

Rajendra Kumar Mundra (HUF), Mumbai vs. National Faceless Assessment Centre (NFAC), Delhi

In the result the appeal filed by the assessee stands allowed

ITA 1000/MUM/2024[2016-17]Status: DisposedITAT Mumbai06 Aug 2025AY 2016-17

Bench: Hon’Ble Shri Sandeep Gosain& Shri Girish Agrawalrajendra Kumar Mundra Vs. Ito, Ward 24(3)(1) (Huf) Piramal Chamber C-28, Ameya Bldg, Behind Lalbaug, Mumbai – Ymca Dn Nagar Andheri (W) 400012. 400053. Pan/Gir No.Aadh6828J (Applicant) (Respondent)

Section 147Section 148Section 2Section 263Section 68Section 69A

basis of report of the PUNE BENCH "A" Investigation wing and non-application of independent mind by the Assessing Officer ITA which amounts to borrowed satisfaction No.2016/PUN/2024 supports his case to the proposition that the reopening of the assessment merely on Assessment year: the basis of report of Investigation Wing ... basis of report of the Investigation wing and non-application of independent mind by the Assessing Officer which amounts to Assessment year: 2016- borrowed satisfaction supports his case 17 to the proposition that the reopening of the assessment merely on the basis of JaibhagwanBanarasidas report of Investigation Wing and Jindal

Ultra Modern Exports Pvt. Ltd., New Delhi vs. ITO Ward - 27(1), New Delhi

ITA 527/DEL/2020[2011-12]Status: DisposedITAT Delhi06 Aug 2025AY 2011-12

Bench: Shri Vikas Awasthy & Shri M. Balaganesh

For Appellant: Shri S. K. Tulsiyan, AdvFor Respondent: Shri Om Prakash, Sr. DR
Section 143(1)Section 143(3)Section 147Section 148Section 68

crores from these two entities. Hence, it could be safely concluded that the entire reopening of the assessment had been made merely on borrowed satisfaction of the investigation wing of Mumbai vide letter dated 16-3-2018 and without having any tangible material. It is trite law that the reasons