borrowed satisfaction — 1,326 case laws

M/S. Nova Home Appliances Pvt Ltd, Mumbai vs. Income Tax Officer 4(3)(1), Mumbai

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

ITA 8329/MUM/2025[2012-13]Status: DisposedITAT Mumbai24 Feb 2026AY 2012-13

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm M/S. Nova Home Appliances Private Income Tax Officer 4(3)(1), Limited, Mumbai Office No.8, Second Floor Ashoka Shopping Center, Vs. G T Hospital Complex, Lt Marg, Mumbai – 400 001 Pan: Aadcn0493N (Appellant) : (Respondent)

For Appellant: Shri Shyam Saboo, CAFor Respondent: Shri Swapnil Choudhari, Sr. AR

Section 133Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 250Section 68Section 69

contended that the reasons recorded by the Ld. AO were not in accordance with law as the same pertained to borrowed satisfaction since in the reasons recorded the Ld. AO has specified that the assessee has obtained loan from M/s. Kalyani Vincom P. Ltd. instead of M/s. LAN Finance ... Frontier Tradecom Pvt. Ltd. and M/s. LAN Finance Pvt. Ltd. Therefore, the argument of the Ld. AR that the reopening was based on borrowed satisfaction does not hold good and hence the said contention is hereby rejected. 9. On the second issue pertaining to the sanction copy not provided

Bharat Kantilal Doshi, Mumbai vs. Deputy Commissioner of Income Tax, Circle 27(1), Navi Mumbai

ITA 7171/MUM/2025[2017-18]Status: DisposedITAT Mumbai23 Feb 2026AY 2017-18

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri Paresh Shaparia, ARFor Respondent: Shri Swapnil Choudhari, Sr. AR

Section 132(4)Section 147Section 148Section 154Section 234ASection 250Section 271(1)(c)Section 68

notice u/s 148 dated 30.03.2021 is issued after the lapse of 4 years. b. The notice issued u/s 148 was based on borrowed satisfaction without any independent enquiry or application of mind and was issued in a mechanical and casual manner merely based of search proceedings in case of Evergreen

Bharat Kantilal Doshi, Mumbai vs. Deputy Commissioner of Income Tax, Circle 27(1), Navi Mumbai

ITA 7170/MUM/2025[2016-17]Status: DisposedITAT Mumbai23 Feb 2026AY 2016-17

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri Paresh Shaparia, ARFor Respondent: Shri Swapnil Choudhari, Sr. AR

Section 132(4)Section 147Section 148Section 154Section 234ASection 250Section 271(1)(c)Section 68

notice u/s 148 dated 30.03.2021 is issued after the lapse of 4 years. b. The notice issued u/s 148 was based on borrowed satisfaction without any independent enquiry or application of mind and was issued in a mechanical and casual manner merely based of search proceedings in case of Evergreen

Bharat Kantilal Doshi, Mumbai vs. Deputy Commissioner of Income Tax, Circle 27(1), Navi Mumbai

ITA 7169/MUM/2025[2014-15]Status: DisposedITAT Mumbai23 Feb 2026AY 2014-15

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

Section 132(4)Section 147Section 148Section 154Section 234ASection 250Section 271(1)(c)Section 68

notice u/s 148 dated 30.03.2021 is issued after the lapse of 4 years. b. The notice issued u/s 148 was based on borrowed satisfaction without any independent enquiry or application of mind and was issued in a mechanical and casual manner merely based of search proceedings in case of Evergreen

Balaji Bullions and Commodities India Private Limited, Mumbai vs. DCIT Central Circle 7(1), Mumbai

The appeal of the Revenue is allowed for statistical purposes

ITA 3755/MUM/2025[2017-18]Status: DisposedITAT Mumbai23 Feb 2026AY 2017-18

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2017-18

For Appellant: Shri Sharwan Kumar Jha, Adv

Section 133ASection 143(1)

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “B” MUMBAI BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND MS. KAVITHA

Ravisum Creative Promotions Pvt. Ltd (Formerly Known As Agro Investment Pvt. Ltd, Mumbai vs. ACIT Cen Cir 8 (11(1), Mumbai

In the result, appeal is allowed

ITA 1616/MUM/2022[2010-11]Status: DisposedITAT Mumbai20 Feb 2026AY 2010-11

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarravisun Creative Promotions Pvt. Ltd., Acit, Formerly Known As Ravisun Agro 6Th Floor, Aaykar Bhavan, Investments Pvt. Ltd. New Marine Lines, Vs. 305, Surat Sadan, Surat Street, Churchgate, Masjit Bunder, Mumbai - 400020 Mumbai – 400049 (Appellant) : (Respondent) Pan No. Aabcr 9224M Appellant By : Ms. Radha Halbe Respondent By : Shri Annavaran Kosuri, Sr.- Dr (Appellant) (Respondent) Date Of Hearing : 17.02.2026 Date Of Pronouncement : 20.02.2026

For Appellant: Ms. Radha HalbeFor Respondent: Shri Annavaran Kosuri, Sr.- DR

Section 143(3)Section 147Section 148Section 14ASection 43B

audit objection wherein, audit party had proposed the subject disallowance u/s. 14A r.w.r. 8D. Thus, she submitted, the reopening having been made on borrowed satisfaction is invalid. Without prejudice, learned counsel submitted, since the assessee had not earned any exempt income during the year Section 14A r.wr.8D would

Jethabhai Gokulbhai Gol, Banaskatha vs. ITO, Ward 1, Palanpur, Banaskantha

Accordingly, the appeal filed by the assessee is dismissed

ITA 2668/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad19 Feb 2026AY 2016-17

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Chetan Agarwal, ARFor Respondent: Shri Rajenkumar M Vasavda, Sr. DR

Section 142(1)Section 144BSection 147Section 148Section 69

fact by upholding action of Ld. AO in re opening of assessment since it is based on invalid, incorrect, insufficient, vague reasons and on borrowed Satisfaction.” Jethabhai Gokulbhai Gol vs. ITO Asst.Year –2016-17 - 2– 3. The brief facts of the case are that the assessee, an individual, filed ... opening of assessment proceedings on the ground that the “reasons” for reopening the assessment proceedings are only a roving enquiry and based on “borrowed satisfaction” on the basis of information received from DCIT, Gandhinagar Circle that assessee has introduced new capital in cash of Rs.82,61,000/-in the firm

Nandita Shaunak Munshaw, Ahmedabad vs. The ITO, Ward-1(3)(1), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1969/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad18 Feb 2026AY 2014-15

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleassessment Year 2014-15

For Appellant: Shri Mehul K. Patel, AdvocateFor Respondent: Shri Amit Pratap Singh, Sr. D.R

Section 115BSection 147Section 234ASection 68

learned NFAC has grievously erred in confirming the re-opening of assessment u/s 147 of the Act, which is only on borrowed satisfaction, and also without disposing off the objections raised by the appellant, and therefore I.T.A No. 1969/Ahd/2025 Nandita Shaunak Munshaw, A.Y. 2014-15 it ought to have been

Income-Tax Officer, Ward-1(3)(1), Ahmedabad vs. Parthiv Jawaharbhai Shah, Ahmedabad

The appeal of the asessee is partly allowed for statistical purposes while Revenue’s appeal is dismissed

ITA 1038/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad18 Feb 2026AY 2013-14

For Appellant: Shri S. N. Soparkar, Sr. Advocate &For Respondent: Shri Rignesh Das, CIT. DR

Section 147Section 148Section 250Section 68

erred in not holding that the reassessment notice issued by Assessing Officer is bad in law and based upon borrowed satisfaction hence deserves to be quashed 6. In the facts and in the circumstances of the case, the Ld. CIT(A) has erred in not holding that the reassessment notice ... made by the Ld.Counsel for the assesee challenged the reopening in the present case on account of following: i. the reopening was based on borrowed satisfaction ii. the objections of the assessee to the reopening were not disposed of by the AO. 7. Several case laws were referred

Parthiv Jawaharbhai Shah, Ahmedabad vs. The ITO, Ward-1(3)(1), Ahmedabad

The appeal of the asessee is partly allowed for statistical purposes while Revenue’s appeal is dismissed

ITA 1030/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad18 Feb 2026AY 2013-14

Bench: SHRI SANJAY GARG (Judicial Member), SMT. ANNAPURNA GUPTA (Accountant Member)

For Appellant: Shri S. N. Soparkar, Sr. Advocate &For Respondent: Shri Rignesh Das, CIT. DR

Section 147Section 148Section 250Section 68

erred in not holding that the reassessment notice issued by Assessing Officer is bad in law and based upon borrowed satisfaction hence deserves to be quashed 6. In the facts and in the circumstances of the case, the Ld. CIT(A) has erred in not holding that the reassessment notice ... made by the Ld.Counsel for the assesee challenged the reopening in the present case on account of following: i. the reopening was based on borrowed satisfaction ii. the objections of the assessee to the reopening were not disposed of by the AO. 7. Several case laws were referred

Exel Rubber Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 1894/HYD/2025[2014-15]Status: DisposedITAT Hyderabad18 Feb 2026AY 2014-15

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita No.1894/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2014-15) M/S. Exel Rubber (P) Ltd Vs. Dy.Cit Hyderabad Central Circle 1(2) Pan:Aaace4495J Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V. Prasad, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 20/01/2026 घोषणा की तारीख/Pronouncement: 18/02/2026 आदेश/Order Per Manjunatha, G. A.M. This Appeal Is Filed By The Assessee Is Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-11 Hyderabad, Dated 11/10/2025 For The A.Y 2014-15. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Narendra Kumar Naik, CIT (DR)

Section 132Section 143(2)Section 143(3)Section 147Section 148Section 149(1)Section 69A

income escaped assessment for the A.Ys 2014-15 to 2018-19. Thus it is a simple case of non-application of mind and a borrowed satisfaction on the part of the Assessing Officer while recording the reasons for reopening. 25. Apart from the non-application of mind regarding the nature

Vilas Polymer Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, all the six appeals i

ITA 1874/HYD/2025[2018-19]Status: DisposedITAT Hyderabad18 Feb 2026AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.1870 To 1875/Hyd/2025 Assessment Years 2014-2015 To 2019-2020 Vilas Polymer Private The Dcit, Limited, Hyderabad. Central Circle-1(2), Vs. Pin – 500 090 Hyderabad – 500 004. Pan Aaacv9854A Telangana. (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca M V Prasad राज" व "ारा /Revenue By: Dr. Narendra Kumar Naik, Cit- Dr सुनवाई की तारीख/Date Of Hearing: 19.01.2026 घोषणा की तारीख/Pronouncement: 18.02.2026 आदेश/Order

For Appellant: CA M V PrasadFor Respondent: Dr. Narendra Kumar Naik, CIT-

Section 132Section 143(3)Section 148Section 149Section 149(1)(b)Section 151

income escaped assessment for the A.Ys 2014-15 to 2018-19. Thus it is a simple case of non-application of mind and a borrowed satisfaction on the part of the Assessing Officer while recording the reasons for reopening. 25. Apart from the non-application of mind regarding the nature

Vilas Polymer Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, all the six appeals i

ITA 1872/HYD/2025[2016-17]Status: DisposedITAT Hyderabad18 Feb 2026AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.1870 To 1875/Hyd/2025 Assessment Years 2014-2015 To 2019-2020 Vilas Polymer Private The Dcit, Limited, Hyderabad. Central Circle-1(2), Vs. Pin – 500 090 Hyderabad – 500 004. Pan Aaacv9854A Telangana. (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca M V Prasad राज" व "ारा /Revenue By: Dr. Narendra Kumar Naik, Cit- Dr सुनवाई की तारीख/Date Of Hearing: 19.01.2026 घोषणा की तारीख/Pronouncement: 18.02.2026 आदेश/Order

For Appellant: CA M V PrasadFor Respondent: Dr. Narendra Kumar Naik, CIT-

Section 132Section 143(3)Section 148Section 149Section 149(1)(b)Section 151

income escaped assessment for the A.Ys 2014-15 to 2018-19. Thus it is a simple case of non-application of mind and a borrowed satisfaction on the part of the Assessing Officer while recording the reasons for reopening. 25. Apart from the non-application of mind regarding the nature

Vilas Polymer Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, all the six appeals i

ITA 1870/HYD/2025[2014-15]Status: DisposedITAT Hyderabad18 Feb 2026AY 2014-15

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.1870 To 1875/Hyd/2025 Assessment Years 2014-2015 To 2019-2020 Vilas Polymer Private The Dcit, Limited, Hyderabad. Central Circle-1(2), Vs. Pin – 500 090 Hyderabad – 500 004. Pan Aaacv9854A Telangana. (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca M V Prasad राज" व "ारा /Revenue By: Dr. Narendra Kumar Naik, Cit- Dr सुनवाई की तारीख/Date Of Hearing: 19.01.2026 घोषणा की तारीख/Pronouncement: 18.02.2026 आदेश/Order

For Appellant: CA M V PrasadFor Respondent: Dr. Narendra Kumar Naik, CIT-

Section 132Section 143(3)Section 148Section 149Section 149(1)(b)Section 151

income escaped assessment for the A.Ys 2014-15 to 2018-19. Thus it is a simple case of non-application of mind and a borrowed satisfaction on the part of the Assessing Officer while recording the reasons for reopening. 25. Apart from the non-application of mind regarding the nature

Deputy Commissioner of Income Tax, Central Circle-1(2), Kolkata vs. M/S Amluckie Investment Company Limited, Kolkata

In the result, both the appeals of the revenue are dismissed

ITA 2542/KOL/2025[2015-16]Status: DisposedITAT Kolkata18 Feb 2026AY 2015-16

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.2541 & 2542/Kol/2025 Assessment Years: 2013-14 & 2015-16 Dcit, Cc-1(2), Kolkata…………..…....…………….……….……….……Appellant Vs. M/S Amluckie Investment Company Ltd.……………….....……...…..…..Respondent 2Nd Floor, 10 Princep Street, Kolkata-700072. [Pan: Aacca6749H] Appearances By: Shri Manoj Kr. Pati, Sr. Dr, Appeared On Behalf Of The Appellant. Shri Miraj D Shah, Ar, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 12, 2026 Date Of Pronouncing The Order : February 18, 2026 Order Per Pradip Kumar Choubey: Both The Present Appeals Filed By The Revenue Are Directed Against Separate Orders Both Dated 21.07.2025 Of The Cit(A)-20, Kolkata Passed U/S 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Years 2013–14 2015-16 Respectively. Since Both The Appeals Relate To The Same Assessee & Arisen From Same Appellate Order, Therefore, These Appeals Were Heard Together & We Are Going To Dispose Of These Appeals By Passing A Consolidated Order. 2. Both The Appeal Filed By The Revenue With A Delay Of 35 Days & The Revenue Has Filed Separate Petitions For Condonation Of The Delays. After Going Over The Said Petitions, We Find Sufficient Reasons Behind Such Delays & Consequently, The Delays In Filing Both The Appeal Are Hereby Condoned & We Proceed To Dispose Of The Appeals On Merits.

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

Sawankumar T. Jajoo (supra) to contend that once primary evidence is furnished the onus shifts to the department and that reassessment premised on borrowed satisfaction and wrong facts is void. After examination of appellant submission and facts of the case, I find the following; 1. the reasons recorded and approval ... wrong in passing an order entirely based on report of investigation wing without making any independent enquiry and the order was passed on borrowed satisfaction. The ld. AR submits that reasons recorded for issuance of notice u/s 148 pertained to alleged artificial trading in the derivatives segment involving

Deputy Commissioner of Income Tax, Central Circle-1(2), Kolkata vs. M/S Amluckie Investment Company Limited, Kolkata

In the result, both the appeals of the revenue are dismissed

ITA 2541/KOL/2025[2013-14]Status: DisposedITAT Kolkata18 Feb 2026AY 2013-14

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.2541 & 2542/Kol/2025 Assessment Years: 2013-14 & 2015-16 Dcit, Cc-1(2), Kolkata…………..…....…………….……….……….……Appellant Vs. M/S Amluckie Investment Company Ltd.……………….....……...…..…..Respondent 2Nd Floor, 10 Princep Street, Kolkata-700072. [Pan: Aacca6749H] Appearances By: Shri Manoj Kr. Pati, Sr. Dr, Appeared On Behalf Of The Appellant. Shri Miraj D Shah, Ar, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 12, 2026 Date Of Pronouncing The Order : February 18, 2026 Order Per Pradip Kumar Choubey: Both The Present Appeals Filed By The Revenue Are Directed Against Separate Orders Both Dated 21.07.2025 Of The Cit(A)-20, Kolkata Passed U/S 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Years 2013–14 2015-16 Respectively. Since Both The Appeals Relate To The Same Assessee & Arisen From Same Appellate Order, Therefore, These Appeals Were Heard Together & We Are Going To Dispose Of These Appeals By Passing A Consolidated Order. 2. Both The Appeal Filed By The Revenue With A Delay Of 35 Days & The Revenue Has Filed Separate Petitions For Condonation Of The Delays. After Going Over The Said Petitions, We Find Sufficient Reasons Behind Such Delays & Consequently, The Delays In Filing Both The Appeal Are Hereby Condoned & We Proceed To Dispose Of The Appeals On Merits.

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

Sawankumar T. Jajoo (supra) to contend that once primary evidence is furnished the onus shifts to the department and that reassessment premised on borrowed satisfaction and wrong facts is void. After examination of appellant submission and facts of the case, I find the following; 1. the reasons recorded and approval ... wrong in passing an order entirely based on report of investigation wing without making any independent enquiry and the order was passed on borrowed satisfaction. The ld. AR submits that reasons recorded for issuance of notice u/s 148 pertained to alleged artificial trading in the derivatives segment involving

Income Tax Officer, Ward-8(2), Kolkata vs. Delighted Holdings Private Limited, Kolkata

In the result, the appeal filed by the revenue is dismissed

ITA 882/KOL/2023[2011-12]Status: DisposedITAT Kolkata18 Feb 2026AY 2011-12

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2011-12 Ito, Ward-8(2), Kolkata…....……..……….………….……….……….……Appellant Vs. Delighted Holdings Pvt. Ltd.…………………………..….....……...…..…..Respondent 12A, Lord Sinha Road, 1St Floor, R No102, Annapurna Apartment, Kol-71. [Pan: Aabce0588P] Appearances By: Shri Sandip Sarkar, Jcit, Appeared On Behalf Of The Appellant. Shri Abhishek Bansal, Ca, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 28, 2026 Date Of Pronouncing The Order : February 18, 2026 Order Per Pradip Kumar Choubey: This Appeal Filed By The Revenue Is Directed Against The Order Dated 23.05.2023 Of The Nfac, Delhi (Hereinafter Referred To As The “Cit(A)”) Passed U/S 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Year 2011–12. 2. The Appeal Has Been Filed By The Assessee With A Delay Of 29 Days & The Assessee Has Filed A Petition For Condonation Of The Delay. After Going Over The Said Petition, We Find Sufficient Reasons For The Delay & Consequently, The Delay In Filing The Appeal Is Hereby Condoned & We Proceed To Dispose Of The Appeal On Merits.

Section 147Section 250

quashed the reopening of assessment u/s 147 on the ground that non-application of mind by the ld. AO as well as on borrowed satisfaction as stated hereinabove. In our opinion, the order passed by the co-ordinate Bench is not suffering from any apparent/ prima facie mistake which warrant

Labh Combines Pvt. Ltd., Kolkata vs. DCIT, Circle 7(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 2382/KOL/2025[2017-2018]Status: DisposedITAT Kolkata17 Feb 2026AY 2017-2018

Bench: SHRI RAJESH KUMAR, ACCOUNTANT MEMBER SHRI PRADIP KUMAR CHOUBEY (Judicial Member)

Section 132Section 132(4)Section 139(1)Section 143(2)Section 143(3)Section 147Section 148Section 148(2)Section 250Section 68

escaped assessment. The conclusions of the AO are at best a reproduction of the conclusion in the investigation report. Indeed, it is a 'borrowed satisfaction'. The reasons fail to demonstrate the link between the tangible material and the formation of the reason to believe that income has escaped assessment ... fishing inquiry. The AO has to apply his mind to the information received by him from the DDIT (Inv.) and cannot act on borrowed satisfaction. It is for this reason that the recorded reasons even does not indicate the amount which according to the Assessing Officer, has escaped Assessment. This

Surana Bros Pvt. Ltd., Kolkata vs. ITO, Ward 12(1), Kolkata

Appeal of the assessee is allowed

ITA 2143/KOL/2025[2009-2010]Status: DisposedITAT Kolkata17 Feb 2026AY 2009-2010

Bench: SHRI RAJESH KUMAR, ACCOUNTANT MEMBER SHRI PRADIP KUMAR CHOUBEY (Judicial Member)

Section 143(2)Section 144Section 147Section 148Section 250

raised in Ground No. 1 is against the order of Ld. CIT(A) confirming reopening of assessment which was made on the basis of borrowed satisfaction without application of mind and without making any enquiry into information received from the AO and thus there was no tangible material to reopen ... return of income. Therefore, reopening of assessment is based on the wrong facts. We note that the AO has merely acted on the borrowed satisfaction without making any enquiry into the information received from Singapore. Thus, this is a case of borrowed satisfaction without application of mind. The case

Quetzal Buildtech Private Limited, Haryana vs. Income Tax Officer, Haryana

ITA 6409/DEL/2025[2016-17]Status: DisposedITAT Delhi17 Feb 2026AY 2016-17

Bench: Shri C.N. Prasad

Section 115BSection 139(1)Section 143(2)Section 147Section 234BSection 68Section 69C

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, ‘SMC”: NEW DELHI BEFORE SHRI C.N. PRASAD, JUDICIAL MEMBER ITA No.6409/Del/2025 Assessment

“borrowed satisfaction”

Leading authorities on borrowed satisfaction

Judgments citing borrowed satisfaction

M/S. Nova Home Appliances Pvt Ltd, Mumbai vs. Income Tax Officer 4(3)(1), Mumbai

Bharat Kantilal Doshi, Mumbai vs. Deputy Commissioner of Income Tax, Circle 27(1), Navi Mumbai

Bharat Kantilal Doshi, Mumbai vs. Deputy Commissioner of Income Tax, Circle 27(1), Navi Mumbai

Bharat Kantilal Doshi, Mumbai vs. Deputy Commissioner of Income Tax, Circle 27(1), Navi Mumbai

Balaji Bullions and Commodities India Private Limited, Mumbai vs. DCIT Central Circle 7(1), Mumbai

Ravisum Creative Promotions Pvt. Ltd (Formerly Known As Agro Investment Pvt. Ltd, Mumbai vs. ACIT Cen Cir 8 (11(1), Mumbai

Jethabhai Gokulbhai Gol, Banaskatha vs. ITO, Ward 1, Palanpur, Banaskantha

Nandita Shaunak Munshaw, Ahmedabad vs. The ITO, Ward-1(3)(1), Ahmedabad

Income-Tax Officer, Ward-1(3)(1), Ahmedabad vs. Parthiv Jawaharbhai Shah, Ahmedabad

Parthiv Jawaharbhai Shah, Ahmedabad vs. The ITO, Ward-1(3)(1), Ahmedabad

Exel Rubber Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

Vilas Polymer Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

Vilas Polymer Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

Vilas Polymer Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

Deputy Commissioner of Income Tax, Central Circle-1(2), Kolkata vs. M/S Amluckie Investment Company Limited, Kolkata

Deputy Commissioner of Income Tax, Central Circle-1(2), Kolkata vs. M/S Amluckie Investment Company Limited, Kolkata

Income Tax Officer, Ward-8(2), Kolkata vs. Delighted Holdings Private Limited, Kolkata

Labh Combines Pvt. Ltd., Kolkata vs. DCIT, Circle 7(1), Kolkata

Surana Bros Pvt. Ltd., Kolkata vs. ITO, Ward 12(1), Kolkata

Quetzal Buildtech Private Limited, Haryana vs. Income Tax Officer, Haryana