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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

ACIT, Circle-34, Kolkata vs. Vinod Kumar Lahoti, Kokata

In the result, the appeal of the revenue is dismissed

ITA 2460/KOL/2024[2013-14]Status: DisposedITAT Kolkata25 Jul 2025AY 2013-14

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 69C

that AO has not made any independent enquiry for reopening of assessment. The Appellant has further argued that reopening of assessment is based on borrowed satisfaction. The Appellant has also submitted that objections to reopening of assessment have not been properly disposed of and the notice has been issued beyond ... Grounds taken by Appellant for failure on part of AO for not making independent enquiries, for opening of assessment on borrowed satisfaction, for chance of opinion have the force as the courts and other judicial forums have held in favor of the assessees from time to time. 6.1.3 The facts

Omprakash Daruka, Raniganj vs. ITO, Ward 3(1), Asansol

In the result, appeal of the assessee is allowed

ITA 685/KOL/2025[2013-2014]Status: DisposedITAT Kolkata24 Jul 2025AY 2013-2014

Bench: Shri George Mathanआयकर अपील सं/Ita No.685/Kol/2025 (नििाारण वर्ा / Assessment Year :2013-2014) Omprakash Daruka, Vs Ito, Ward-3(1), Asansol C/O S.N.Ghosh & Associates, Advocates, 2, Garstin Place, 2Nd Floor, Suite No.203, Off Hare Street Kolkata-700001 Pan No. : Acqpd 1122 L (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) : Shri Somnath Ghosh, Ar नििााररती की ओर से /Assessee By राजस्व की ओर से /Revenue By : Shri Shankar Naskar, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 24/07/2025 घोषणा की तारीख/Date Of Pronouncement : 24/07/2025 आदेश / O R D E R

For Respondent: Shri Shankar Naskar, Sr. DR
Section 147Section 148Section 148(2)Section 149Section 151

therefore, the reasons recorded were not sufficient as the AO has not recorded his satisfaction and it is, in fact, a case of borrowed satisfaction. The case of the assessee find support from the decision of CIT Vs. Insecticides (India) Ltd. (supra), wherein the Hon'ble Court in para

DCIT, Circle-I, Ludhiana vs. Adinath Textiles Limited, Ludhiana

In the result both the appeal filed by the Revenue and Cross objection filed by the Assessee are dismissed

ITA 122/CHANDI/2024[2012-13]Status: DisposedITAT Chandigarh23 Jul 2025AY 2012-13

Bench: the appeal is finally heard or disposed off.

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR
Section 147Section 148Section 68Section 69C

suspicion and doubt. 4. That the confirmation of addition u/s 148 is not valid since the reopening has been resorted to only on borrowed satisfaction without any application of mind by the Assessing Officer, which is not permitted as per law. 5. That the cross objector creates leave ... from the DCIT, Kolkata without any application of mind by the AO. No enquiries have been made and, thus, it was a case of borrowed satisfaction. Reliance was made on the following judgments:- i). CIT vs Meenakshi Overseas Ltd. as reported in 395 ITR 677, ii). PCIT

Chanderkumar Omprakash HUF, Navi Mumbai vs. Income Tax Officer, Vashi

In the result, grounds of appeal of assessee

ITA 2331/MUM/2025[2012-13]Status: DisposedITAT Mumbai23 Jul 2025AY 2012-13

Bench: Shri Pawan Singh(Physical Hearing) Chanderkumaromprakash Huf Ito,Ward– 28(1)(3), Mumbai Revenue-22, Apmc Market, Phase Ii, Vs Vashi Railway Station, Vashi, Turbhe, Navi Mumbai – 400705. Navi Mumbai-400705. [Pan No. Aabhc5968A] Appellant / Assessee Respondent / Revenue

Section 143(3)Section 148Section 151Section 250Section 254(1)

turn is based on generalized statement of third party who has not named the Appellant in his statement and hence it is a borrowed satisfaction and not the own satisfaction of the Ld. Assessing Officer Ground No.3: Section 151: In Facts and circumstance of the case

Basant Aerospace Private Limited, New Delhi vs. ACIT Central Circle-5, New Delhi

In the result, the appeal of the Assessee for assessment year 2016-17

ITA 2292/DEL/2023[2016-17]Status: DisposedITAT Delhi23 Jul 2025AY 2016-17

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri V. K. Agarwal, AdvFor Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 131Section 133Section 143(1)Section 147Section 148Section 68

quashing the reassessment proceedings framed for the assessment year 2012-13 as it is based on (a) incorrect assumption of facts; (b) based on borrowed satisfaction and (c) approval granted under section 151 of the Act ITA Nos. 520 & 2292/Del/2023 M/s. Basant Aerospace Pvt. Ltd by the competent authority

Basant Aerospace Pvt Ltd, New Delhi vs. ACIT Central Circle-5, New Delhi

In the result, the appeal of the Assessee for assessment year 2016-17

ITA 520/DEL/2021[2012-13]Status: DisposedITAT Delhi23 Jul 2025AY 2012-13

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri V. K. Agarwal, AdvFor Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 131Section 133Section 143(1)Section 147Section 148Section 68

quashing the reassessment proceedings framed for the assessment year 2012-13 as it is based on (a) incorrect assumption of facts; (b) based on borrowed satisfaction and (c) approval granted under section 151 of the Act ITA Nos. 520 & 2292/Del/2023 M/s. Basant Aerospace Pvt. Ltd by the competent authority

Bangalore Venkatappa Ravikumar, Bangalore vs. ACIT, Circle-6(3)(1), Bangalore

In the result, the appeals of the assessee for both the years are allowed for statistical purposes as directed above

ITA 800/BANG/2025[2017-18]Status: DisposedITAT Bangalore22 Jul 2025AY 2017-18

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

For Appellant: Shri Avinash Mallya, CAFor Respondent: Shri Balusamy N., Jt.CIT (DR)(ITAT), Bengaluru
Section 131Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 271(1)(b)Section 69A

before the ld. CIT(A). The assessee objected to the reopening of the assessment stating that reopening has been made on the basis of borrowed satisfaction as information obtained from JCIT, Range 3(2) was utilised for reopening. The ld. CIT(A) categorically rejected the same for the reason that ... Bank and deposited cash of Rs.76,20,000. Thus reopening was held to be based on tangible material on record and not borrowed satisfaction. The ld. CIT(A) further supported his decision based on various decisions of the Hon’ble Supreme Court. 6. With respect to the other grounds

Bangalore Venkatappa Ravikumar, Bangalore vs. ACIT, Circle-6(3)(1), Bangalore

In the result, the appeals of the assessee for both the years are allowed for statistical purposes as directed above

ITA 799/BANG/2025[2012-13]Status: DisposedITAT Bangalore22 Jul 2025AY 2012-13

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

For Appellant: Shri Avinash Mallya, CAFor Respondent: Shri Balusamy N., Jt.CIT (DR)(ITAT), Bengaluru
Section 131Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 271(1)(b)Section 69A

before the ld. CIT(A). The assessee objected to the reopening of the assessment stating that reopening has been made on the basis of borrowed satisfaction as information obtained from JCIT, Range 3(2) was utilised for reopening. The ld. CIT(A) categorically rejected the same for the reason that ... Bank and deposited cash of Rs.76,20,000. Thus reopening was held to be based on tangible material on record and not borrowed satisfaction. The ld. CIT(A) further supported his decision based on various decisions of the Hon’ble Supreme Court. 6. With respect to the other grounds

Bhadresh Mansukhlal Dodhia, Bhiwandi vs. DCIT-CC-3, Thane

In the result, the appeal of the assesseeis allowed

ITA 2218/MUM/2025[2013-14]Status: DisposedITAT Mumbai22 Jul 2025AY 2013-14

Bench: Shri Pawan Singh(Physical Hearing) Bhadresh Mansukhlal Dodhia Dcit – Cc-3, Thane 60/100, New Mavji Compound Behind Vs Room No. 12, A Wing, 6Th Floor, Ashar It Park, Ratan, Talkies Narpoli Bhiwandi, Maharashtra-421302. Thane West, [Pan No. Afhpd2871E] Maharashtra-400604. Appellant / Assessee Respondent / Revenue

Section 143(3)Section 153ASection 254(1)Section 37Section 68

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 on the part of the Ld. Assessing Officer. 12. On the facts and in the circumstances of the appellant

Amit Behal, New Delhi vs. ACIT, Circle Int. Taxation 1(1) (2), New Delhi

In the result, the appeal of the assessee in ITA No

ITA 923/DEL/2024[2015-16]Status: DisposedITAT Delhi18 Jul 2025AY 2015-16

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Tushar Hemani, Sr. AdvFor Respondent: Shri Vizay B. Vasanta, CIT-DR
Section 148Section 148ASection 69Section 69A

Secondly, the ld AR attacked the order u/s 148A(d) as vague, scanty and non-specific and that the reopening is merely based on borrowed satisfaction. The ld AR relied on ➤ Signature Hotels P. Ltd. vs. ITO – (2012) 338 ITR 51 (Delhi); ➤ Harikishan S. Virmani vs DCIT ... assessment under the new amended law of section 148 and 148A. Under the amended provision, the concept of ‘reason to believe’, and ‘borrowed satisfaction’ has been replaced with ‘information’ from RMS which suggest escapement of income above Rs 50 lakh. In the instant case, the JAO had in his possession

ACIT, New Delhi vs. M/S. Alodie Estates Pvt. Ltd., New Delhi

In the result, the appeal of the revenue is dismissed

ITA 1730/DEL/2016[2011-12]Status: DisposedITAT Delhi18 Jul 2025AY 2011-12

Bench: Shri Sudhir Kumar & Shri Manish Agarwalassessment Year: 2011-12 Asstt. Commissioner Of Vs. M/S. Alodie Estates Pvt. Ltd. 2Nd Income Tax, Central B-4/43, Floor, Safdarjung Circle-2, New Delhi Enclave, New Delhi-110029 Pan No.Aaica1782G (Appellant) (Respondent)

Section 132Section 139Section 147Section 148Section 68

find no infirmity in the order of Ld.CIT(A) in holding the re-opening of assessment as invalid which is solely based on the borrowed satisfaction. Accordingly, the additional ground taken by the Revenue is dismissed. 10. With regard to the grounds taken on merits of the addition

Jaiprakash Yadav, Alwar vs. Income Tax Officer, WD, Behror

In the result, the appeal of the assessee is allowed

ITA 18/JPR/2025[2016-17]Status: DisposedITAT Jaipur15 Jul 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri Pranav Yadav, Adv. (Thr.VC)For Respondent: Shri Gaurav Awasthi, JCIT, Sr. DR
Section 147Section 148Section 151Section 56(2)(vii)Section 69Section 69A

held that such reopening which was based merely on the information received from Investigation. Wing without independent application of mind by A.O. amounted to "borrowed satisfaction" and such reopening was liable to be quashed. 2.7. The head note in the case of Pr. CIT v RMG Polyvinyl ... assessee in addition to the written submission filed vehemently argued that ld. AO has re-opened the case of the assessee on borrowed satisfaction as is evident from the reasons recorded. The ld. AR of the assessee also argued that in the case of the assessee, it is very much

Shri Pachamuthu Ravi, Chennai vs. DCIT, Circle-1(3), Chennai

ITA 2346/CHNY/2024[2014-15]Status: DisposedITAT Chennai15 Jul 2025AY 2014-15
Section 143(2)Section 143(3)Section 147Section 148Section 148(1)Section 2(22)(e)

आयकर अपीलीय अधिकरण, 'बी' न्यायपीठ, चेन्नई। IN THE INCOME TAX APPELLATE TRIBUNAL 'B' BENCH: CHENNAI श्री एबी टी. वर्की, न्यायिक

Malani Holdings Private Limited, Raipur vs. Income Tax Officer, Ward 4(1), Raipur

The appeal of the assessee is dismissed, in terms of our aforesaid observations

ITA 316/RPR/2025[2013-14]Status: DisposedITAT Raipur14 Jul 2025AY 2013-14

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 316/Rpr/2025 (िनधा"रण वष" Assessment Year: 2013-14)

For Appellant: Shri Praveen Khandelwal & Praveen GoyalFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 142(1)Section 143(2)Section 143(3)Section 144Section 147Section 148Section 14ASection 250Section 251(1)(a)Section 68

आयकरअपीलीयअिधकरण, रायपुर "ायपीठ,रायपुर IN THE INCOME TAX APPELLATE TRIBUNAL RAIPUR BENCH, RAIPUR "ी पाथ" सारथी चौधर", "ाियक सद" एवं "ीअ

M/S Vinayak Financial Consultants Private Limited, Kolkata vs. D.C.I.T., Central Circle-4(1), Kolkata

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

ITA 2695/KOL/2024[2013-14]Status: DisposedITAT Kolkata10 Jul 2025AY 2013-14

Bench: Shri George Mathan

For Appellant: Shri A.K.Tulsyan & Shri RobinFor Respondent: Smt. Madhumita Das, Sr.DR
Section 139(1)Section 143(1)Section 147Section 148

other reason. You have relied only on the Information shared by another officer. This means you have placed your reliance solely on the borrowed satisfaction without conducting any independent enquiry and applying your own mind. The formation of opinion in the absence of any real Page | 4 7 ITA No.2695/KOL/2024 ... insight portal/other AO are merely allegations and can't be a credible information. Thus the satisfaction recorded by you is simply a borrowed satisfaction. It is simply an allegation based on mere suspicion without proper "reason to believe". It is evident from the reasons that apart from the information, there

Jitendra Sharma, ACIT, Circle-19(1), Mumbai vs. Kashyap Mahesh Vora, Mumbai

In the result, the appeal of the revenue bearing ITA No

ITA 4322/MUM/2024[2012]Status: DisposedITAT Mumbai10 Jul 2025

Bench: BEFOR SHRI ANIKESH BANERJEE (Judicial Member), SMT. RENU JAUHRI (Accountant Member)

For Appellant: Shri K. Gopal a/w Shri AkhileshFor Respondent: Shri Hemanshu Joshi, SR DR
Section 143(3)Section 147Section 250Section 68Section 69C

record in light of the facts and circumstances of the case and forms an independent opinion in the matter that is not based on borrowed satisfaction. If the opinion is formed solely and mechanically relying upon the 7 Shri Kashyap Mahesh Vora information received from another source, then the assumption

Shyama Shree, Asansol vs. I.T.O., Ward - 1(1), Asansol

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 967/KOL/2025[2013-2014]Status: DisposedITAT Kolkata09 Jul 2025AY 2013-2014

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 143(3)Section 147Section 148Section 250Section 69A

ground no. 1 raised by the assessee relating to reopening. The other ground relating to I.T.A. No.: 967/KOL/2025 Assessment Year: 2013-14 Shyama Shree. borrowed satisfaction was also dismissed after considering the following judicial pronouncements: i) Peass Industrial Engineers 73 Taxmann 185 (Gujarat) ii) Meghavi Minerals

R.D. Vohra HUF, New Delhi vs. PCIT, Faridabad

In the result, the application for condonation of delay of 165 days in filing

ITA 4948/DEL/2024[2015-16]Status: DisposedITAT Delhi09 Jul 2025AY 2015-16

Bench: Shri Shamim Yahya & Shri Vimal Kumar

For Appellant: Shri Rajkumar Gupta, CA & Shri J.PFor Respondent: Ms. Monika Singh, CIT (DR)
Section 142(1)Section 147Section 148Section 151Section 263

reasons are factually incorrect. Hence approval given on incorrect facts is ITA No.4948/Del/2024 also invalid, unsustainable, mechanical, without application of mind and on borrowed satisfaction. On the basis of such fatally defective approvals U/s.151 no legally valid asstt. order U/s.147 can be passed. Since in this case the initiation U/s.147

Shri Gaurav Palriwal, Ranchi vs. ACIT Central Circle -1, Ranchi

In the result, all the captioned appeals of the assessee are allowed

ITA 121/RAN/2024[2011-12]Status: DisposedITAT Ranchi07 Jul 2025AY 2011-12

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayit(Ss)A No. 10 & 11/Ran/2023 (Assessment Year-2012-13 & 2013-14) Sri Vishal Palriwal, A.C.I.T., Ishatvam, Flat No. 801, 8Th Floor, Central Circle-1 Vs. Kanke Road, Ranchi-834008. Ranchi. Pan No. Ahnpp 0913 H Appellant/ Assessee Respondent/ Revenue It(Ss)A No. 12/Ran/2023 (Assessment Year-2012-13) Sri Gaurav Palriwal, A.C.I.T., Flat No. 701, 7Th Floor, Ishatvam, Central Circle-1 Vs. Behind Kanke Petrol Pump, Kanke Ranchi. Road, Ranchi-834008. Pan No. Aiapp 8110 E Appellant/ Assessee Respondent/ Revenue It(Ss)A No. 13/Ran/2023 (Assessment Year-2013-14) Sri Saurav Palriwal, A.C.I.T., Block No. 1, Flat No. 3C, Space Town Central Circle-1 Vs. Vip Road, Raghunathpur, Kolkata. Ranchi. Pan No. Atcpp 9277 D Appellant/ Assessee Respondent/ Revenue It(Ss)A No. 14/Ran/2023 (Assessment Year-2013-14) Smt. Priti Palriwal, A.C.I.T., Flat No. 701, 7Th Floor, Ishatvam, Central Circle-1 Vs. Behind Kanke Petrol Pump, Kanke Ranchi. Road, Ranchi-834008. Pan No. Amdpp 5673 K Appellant/ Assessee Respondent/ Revenue It(Ss)A No. 15/Ran/2023 (Assessment Year-2013-14) Smt. Renu Palriwal, A.C.I.T., Block No. 1, Flat No. 3C, Space Town Central Circle-1 Vs. Vip Road, Raghunathpur, Ranchi. Kolkata-700052 Pan No. Ajlpp 9129 K Appellant/ Assessee Respondent/ Revenue

Section 148Section 151Section 153A

initio void since the same has been initiated on information received from the investigation unit which can only tantamount to be borrowed satisfaction and reason to suspect. The reasons recorded by itself cannot be concluded to be the reasons to believe recorded by the AO on its own application

Smt Renu Palriwal, Kolkata vs. ACIT Central Circle-1, Ranchi

In the result, all the captioned appeals of the assessee are allowed

ITA 66/RAN/2023[2013-14]Status: DisposedITAT Ranchi07 Jul 2025AY 2013-14

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayit(Ss)A No. 10 & 11/Ran/2023 (Assessment Year-2012-13 & 2013-14) Sri Vishal Palriwal, A.C.I.T., Ishatvam, Flat No. 801, 8Th Floor, Central Circle-1 Vs. Kanke Road, Ranchi-834008. Ranchi. Pan No. Ahnpp 0913 H Appellant/ Assessee Respondent/ Revenue It(Ss)A No. 12/Ran/2023 (Assessment Year-2012-13) Sri Gaurav Palriwal, A.C.I.T., Flat No. 701, 7Th Floor, Ishatvam, Central Circle-1 Vs. Behind Kanke Petrol Pump, Kanke Ranchi. Road, Ranchi-834008. Pan No. Aiapp 8110 E Appellant/ Assessee Respondent/ Revenue It(Ss)A No. 13/Ran/2023 (Assessment Year-2013-14) Sri Saurav Palriwal, A.C.I.T., Block No. 1, Flat No. 3C, Space Town Central Circle-1 Vs. Vip Road, Raghunathpur, Kolkata. Ranchi. Pan No. Atcpp 9277 D Appellant/ Assessee Respondent/ Revenue It(Ss)A No. 14/Ran/2023 (Assessment Year-2013-14) Smt. Priti Palriwal, A.C.I.T., Flat No. 701, 7Th Floor, Ishatvam, Central Circle-1 Vs. Behind Kanke Petrol Pump, Kanke Ranchi. Road, Ranchi-834008. Pan No. Amdpp 5673 K Appellant/ Assessee Respondent/ Revenue It(Ss)A No. 15/Ran/2023 (Assessment Year-2013-14) Smt. Renu Palriwal, A.C.I.T., Block No. 1, Flat No. 3C, Space Town Central Circle-1 Vs. Vip Road, Raghunathpur, Ranchi. Kolkata-700052 Pan No. Ajlpp 9129 K Appellant/ Assessee Respondent/ Revenue

Section 148Section 151Section 153A

initio void since the same has been initiated on information received from the investigation unit which can only tantamount to be borrowed satisfaction and reason to suspect. The reasons recorded by itself cannot be concluded to be the reasons to believe recorded by the AO on its own application