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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

M/S Mississippi It Services Privte Limited, Mumbai vs. Deputy Commissioner of Income Tax -Circle 1, Thane

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

ITA 5549/MUM/2024[2013-14]Status: DisposedITAT Mumbai30 Apr 2025AY 2013-14

Bench: Ms. Padmavathy S. & Shri Raj Kumar Chauhanm/S. Mississippi It Services Dcit Circle-1, Private Limited. Qureshi Mansion Road, 215, New Nirmal Nagar, Jantanagar Vs. Thane, Maharashtra – 400 Road, Nr. Station, Nr. Podar School, 604 Bhayander West, Thane, Maharashtra - 401101 Pan: Aagcm4216K (Appellant) (Respondent)

Section 142(1)Section 143(3)Section 147Section 148Section 250Section 271(1)(c)

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “J(SMC)”, MUMBAI BEFORE MS. PADMAVATHY S., ACCOUNTANT MEMBER AND SHRI RAJ

Infobeans Technologies Limited, Indore, M.P vs. The Principal Commissioner of Income-Tax, Indore - 1, Indore, M.P

In the result, the appeal filed by the assessee is dismissed being devoid of

ITA 371/IND/2024[2018-19]Status: DisposedITAT Indore29 Apr 2025AY 2018-19

Bench: Sh. Bhagirath Mal Biyani & Sh. Udayan Dasgupta

For Appellant: S/Sh.SN Agrawal & Ritesh Jain, ARs
Section 143(3)Section 14ASection 14A(2)Section 154Section 263

rectification u/s 155. The Ld AR argued that the said action is proof that the Ld PCIT assumed jurisdiction u/s 263 subsequently on borrowed satisfaction from the AO concerned ,which is not permissible under the Act 61, and some of the judgments relied upon for support are as under ... claim ,he needs to proceed to the formula as laid out in Rule 8D. 26. Regarding the issue of assumption of jurisdiction on borrowed satisfaction vis a vis notice u/s 155, as alleged by the assessee, we find that that it was proposed rectification initiated

ACIT 4 2 1, Mumbai City vs. Iifl Securities, Mumbai City

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

ITA 737/MUM/2025[2016-17]Status: DisposedITAT Mumbai29 Apr 2025AY 2016-17

Bench: Shri Vikram Singh Yadav & Shri Sandeep Gosain

For Appellant: Shri Pritesh MehtaFor Respondent: Shri Chetan M. Kacha
Section 143(2)Section 143(3)Section 147Section 148Section 68

alleged transactions, raising questions about the adequacy of the reasons for reopening. While the procedural requirements under Section 147 were met, the reliance on "borrowed satisfaction without any corroborative inquiry and transactional analysis weakens the substantive validity of the reassessment. 6.4. On the merits of additions (Grounds

ACIT-4 2 1, Mum vs. Iifl Securities Ltd, Mumbai City

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

ITA 722/MUM/2025[2016-17]Status: DisposedITAT Mumbai29 Apr 2025AY 2016-17

Bench: Shri Vikram Singh Yadav & Shri Sandeep Gosain

For Appellant: Shri Pritesh MehtaFor Respondent: Shri Chetan M. Kacha
Section 143(2)Section 143(3)Section 147Section 148Section 68

alleged transactions, raising questions about the adequacy of the reasons for reopening. While the procedural requirements under Section 147 were met, the reliance on "borrowed satisfaction without any corroborative inquiry and transactional analysis weakens the substantive validity of the reassessment. 6.4. On the merits of additions (Grounds

Arenja Industries Private Limited, Mumbai vs. ITO, WD 1(1)(3), Mumbai

In the result, the appeal of the assessee is dismissed as withdrawn

ITA 6754/MUM/2024[20009-10]Status: DisposedITAT Mumbai29 Apr 2025

Bench: Ms. Kavitha Rajagopal & Smt. Renu Jauhriआयकर अपील सं./Ita No. 6754/Mum/2024 (निर्धारण वर्ा / Assessment Year :2009-10) Arenja Industries Pvt. Ltd. V/S. Ito Ward 1(1)(3), Mumbai 507, Sharda Chambers, 15 बिधम Aayakar Bhavan, Maharshi New Marine Lines, Karve Road, Mumbai, Mumbai, Maharashtra- 400020 Maharashtra- 400021 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaaca3369F Appellant/अपीलधर्थी .. Respondent/प्रनिवधदी

For Appellant: Shri Rahul HakaniFor Respondent: Shri Shekhar L. Gajbhiye
Section 250Section 68

erred in confirming the validity of reopening without appreciating and reopening is done by AO on borrowed satisfaction without any independent Application of Mind and on also on the basis of statement of third party and hence reopening is bad in law. 5) The Ld CIT(A) erred in confirming

ACIT, Mumbai vs. Reliance Industries Limited, Mumbai

In the result, the appeal of the Revenue is dismissed whereas the cross-objection of the assessee is allowed

ITA 3705/MUM/2024[2014-15]Status: DisposedITAT Mumbai29 Apr 2025AY 2014-15

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2014-15 Acit, Reliance Industries Ltd., Room No. 559, 5Th Floor, 3Rd Floor Maker Chamber Iv, Aayakar Bhavan, New Marine Vs. Nariman Point, S.O. Lines, Mumbai-400021. Mumbai-400020. Pan No. Aaacr 5055 K Appellant Respondent

For Appellant: Mr. Madhur Agarwal/Ms. MokshaFor Respondent: Ms. Sanyogita Nagpal, CIT-DR
Section 10ASection 115JSection 144BSection 144CSection 147Section 801B(9)

assessee to disclose fully and truly all material facts necessary for assessment; thirdly, (iii) the reasons recorded for reopening were based on 'borrowed satisfaction' from the C&AG audit; and fourthly, (iv) the issues raised in the reasons for reopening were already the subject matter of appellate proceedings. 3.4 Although ... issue in dispute. 7.12 The reassessment qua the addition has been further assailed on the ground that reopening has been based on the borrowed satisfaction based on audit objections. The relevant finding of the Ld. CIT(A) is reproduced as under : “In the case of the appellant, the revenue audit

Mohanbhai Savjibhai Vegad, Vadodara vs. Income Tax Officer, Veraval

ITA 71/RJT/2025[2009-10]Status: DisposedITAT Rajkot28 Apr 2025AY 2009-10
For Appellant: Shri Chetan Agarwal, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)
Section 143(3)Section 148

Income tax (Appeals), National Faceless Appeal Centre has erred in law and facts in ignoring the fact that the assessment was founded on borrowed satisfaction; 1.3 Ld. Commissioner of Income tax (Appeals), National Faceless Appeal Centre has erred in law and facts in ignoring the sworn-in-affidavit of appellant

Manishkumar Ramlakhan Agrawal, Ahmedabad vs. Ward 6(1)(1) Ahmedabad, Ahmedabad

In the result, impugned notice is quashed

ITA 1738/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad25 Apr 2025AY 2016-17

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 10(38)Section 115BSection 132Section 143(1)Section 143(2)Section 144Section 147Section 148Section 69A

Return of Income filed by the assessee. In the above circumstances the very reopening of assessment itself is invalid in law based on the “borrowed satisfaction” from investigation wing of the department. 9. The Jurisdictional High Court in the case of Ashishbhai Jashwantbhai Desai HUF vs. ITO in R/Special Civil ... forming such belief. 9. Therefore, it is clear that the respondent-Assessing Officer has recorded the reasons only on the basis of the borrowed satisfaction without there being any live-link between the information available on the Insight Portal and the data available on the record of the petitioners- assesses

Raudramukhi Commerce Pvt. Ltd., Kolkata vs. I.T.O., Ward - 4(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 2023/KOL/2024[2013-2014]Status: DisposedITAT Kolkata24 Apr 2025AY 2013-2014

Bench: Shri Rajesh Kumar, Am Raudramukhi Commerce Pvt. Ltd. I.T.O., Ward - 4(1) C/O. S.N. Ghosh & Associates, Aayakar Bhawan, P-7, Advocates, 2, Garstin Place, Chowringhee Square, Kolkata, Vs. 2Nd Floor, Suite No.203, West Bengal, 700069 Off Hare Street, Kolkata, West Bengal, 700001 (Appellant) (Respondent) Pan No. Aafcr6446R Assessee By : Shri Somnath Ghosh & Shri Sarnath Ghosh, Ars Revenue By : Ms. Madhumita Das, Dr Date Of Hearing: 17.04.2025 Date Of Pronouncement : 24.04.2025

For Appellant: Shri Somnath Ghosh &For Respondent: Ms. Madhumita Das, DR
Section 147Section 148Section 148(2)Section 68

information received by him from the Investigation Wing with the Income-Tax Return/accounts of the assessee. He reopened the assessment on the basis of borrowed satisfaction without verifying about the genuineness of the information received. Such an information from Investigation Wing may give the Assessing Officer the reasons to suspect ... quash the reopening of assessment order for the reasons of non-recording of any reason to believe and re-opening the case on borrowed satisfaction. 10. In the result, the appeal of the assessee is allowed.” Accordingly, I am inclined to quash the reopening of assessment. 08. In the result

General Motors Technical Centre India Private Limited, Haryana vs. DCIT, Circle-1(1), Gurgaon

In the result, Appeal of the Assessee in ITA Nos

ITA 459/DEL/2022[2017-18]Status: DisposedITAT Delhi24 Apr 2025AY 2017-18

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 131Section 132ASection 147Section 69

that the A.O. assumed jurisdiction u/s 147 of the Act on 4ITA Nos. 459 to 462/Del/2019 Suresh Chand Goel Vs. ITO the basis of borrowed satisfaction Investigation Wing, whereinthe A.O. had made no independent enquiry and approval has been granted in mechanical manner by the PCIT

General Motors Technical Centre India Pvt Ltd, Gurugram vs. ACIT, Circle, 1(1), Gurugram

In the result, appeal filed by the assessee is allowed

ITA 2215/DEL/2022[2018-19]Status: DisposedITAT Delhi24 Apr 2025AY 2018-19

Bench: Shris.Rifaur Rahmansunita Sarda, Vs. Acit, Circle 71 (1), 5/5761, Dev Nagar, Karol Bagh, New Delhi. New Delhi – 110 005. (Pan : Aanps7143M) (Appellant) (Respondent) Assessee By : Ms. Vidhi Mangla, Advocate Revenue By : Shri Sanjay Kumar, Sr. Dr Date Of Hearing : 12.03.2025 Date Of Order : 14.05.2025 O R D E R 1. This Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income-Tax Appeals/National Faceless Appeal Centre (Nfac), Delhi (Hereinafter Referred To ‘Ld. Cit (A)’) Dated 06.06.2023 For Assessment Year 2011-12. 2. Brief Facts Of The Case Are, Assessee Has Filed Her Return Of Income For The Year Under Consideration On 29.09.2011 Declaring Total Income Of Rs.4,42,000/-. The Department Has Received Information From Office Of Ddit (Inv.), Unit 6 (3), New Delhi On 06.03.2018 That The Assessee Has Taken Bogus Accommodation Entry Amounting To Rs.17,25,000/- During Fy 2010-11 By Trading In The Penny Scrip I.E. M/S. Global Capital

For Appellant: Ms. Vidhi Mangla, AdvocateFor Respondent: Shri Sanjay Kumar, Sr. DR
Section 10Section 10(38)Section 115BSection 142(1)Section 143(2)Section 148Section 68

solely relied upon the information received from the DDIT(Inv.), Unit-6(3), New Delhi without any independent application of mind resulting in borrowed satisfaction contrary to settled law and therefore rendering the impugned proceedings u/ s 147 r.w.s 143(3) of the Act null and void on account

Miker Financial Consultants Pvt. Ltd., Mumbai vs. Ward-10(2)(4), Mumbai

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

ITA 849/MUM/2024[2017-18]Status: DisposedITAT Mumbai23 Apr 2025AY 2017-18

Bench: SHRI VIKRAM SINGH YADAV (Accountant Member), SHRI SANDEEP SINGH KARHAIL (Judicial Member)

Section 144Section 151Section 250Section 68Section 69C

contrary to the facts of the case and reopening of assessment is without any application of mind and merely reason to suspect based on borrowed satisfaction without any tangible material and no such material or evidence or any other documents furnished to the Appellant and hence, the reopening

DCIT Central Circle-1(1), Mumbai vs. R C Gems, Bandra

In the result, all the appeals of the Revenue as well as Cross Objections of the assessee are dismissed

ITA 813/MUM/2025[2019-20]Status: DisposedITAT Mumbai22 Apr 2025AY 2019-20

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 143(3)

Before us ld. Counsel submitted that first of all the reopening in the case of the assessee was based on borrowed satisfaction without any enquiry or verification by the ld. AO. Secondly, Director / employees of Ratnakala Exports Private Limited have R.C.Gems given a general statement and not specifically identified

DCIT Central Circle-1(1), Mumbai vs. R C Gems, Bandra

In the result, all the appeals of the Revenue as well as Cross Objections of the assessee are dismissed

ITA 812/MUM/2025[2020-21]Status: DisposedITAT Mumbai22 Apr 2025AY 2020-21

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 143(3)

Before us ld. Counsel submitted that first of all the reopening in the case of the assessee was based on borrowed satisfaction without any enquiry or verification by the ld. AO. Secondly, Director / employees of Ratnakala Exports Private Limited have R.C.Gems given a general statement and not specifically identified

DCIT Central Circle-1(1), Mumbai vs. R C Gems, Bandra(East

In the result, all the appeals of the Revenue as well as Cross Objections of the assessee are dismissed

ITA 721/MUM/2025[2022-23]Status: DisposedITAT Mumbai22 Apr 2025AY 2022-23

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 143(3)

Before us ld. Counsel submitted that first of all the reopening in the case of the assessee was based on borrowed satisfaction without any enquiry or verification by the ld. AO. Secondly, Director / employees of Ratnakala Exports Private Limited have R.C.Gems given a general statement and not specifically identified

Marie Products Private Limited, Jaipur vs. Assistant Commissioner of Income Tax, Circle 7, Jaipur

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

ITA 771/JPR/2023[2018-19]Status: DisposedITAT Jaipur21 Apr 2025AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. P. C. Parwal, CAFor Respondent: Sh. Ajay Malik, CIT
Section 14Section 142(1)Section 143(3)

factory of the Appellant without bill. Thus, the addition made by the AO under section 69C is incorrect and be deleted. Addition basis borrowed satisfaction without independent examination cannot be made 32. The AO should have independently examined the alleged suppressed production and the information from the show cause notice

ACIT, Circle-5.1, Kolkata vs. Yadav Prasad Tosniwal, Kolkata

In the result, appeal of the revenue is dismissed

ITA 1730/KOL/2024[2010-11]Status: DisposedITAT Kolkata21 Apr 2025AY 2010-11

Bench: Shri Rajesh Kumarआयकर अपील सं/Ita No.1730/Kol/2024 (नििाारण वर्ा / Assessment Years : 2010-2011) Acit, Circle-5.1, Kolkata Vs Yadav Prasad Tosniwal, 638, Basanmoyee Apartment Rabindra Sarani, Bagbazar, Kolkata-700003 Pan No. :Acipt6576E (अपीलार्थी /Appellant) (प्रत्यर्थी / Respondent) .. राजस्वकीओरसे /Revenue By : Ms. Madhumita Sas, Addl.Cit नििााररतीकीओरसे /Assessee By : Shri Siddharth Kejriwal, Ar सुनवाई की तारीख / Date Of Hearing : 17/04/2025 घोषणा की तारीख/Date Of Pronouncement : 21/04/2025 आदेश / O R D E R This Is The Appeal Filed By The Revenue Against The Order Dated 18.03.2024, Passed By The Ld. Cit(A), National Faceless Appeal Centre, (Nfac), Delhi For The Assessment Year 2010-2011. 2. As Per The Office Record, It Is Noted That The Appeal Is Filed Belatedly By 89 Days. In This Regard, The Revenue Has Filed Condonation Application Stating Therein Sufficient Reasons For Condonation Of Delay. Considering The Reasons Stated In The Application Of The Revenue, The Delay Of 89 Days In Filing The Present Appeal Is Condoned & The Appeal Is Admitted For Hearing. 3. The Revenue Has Raised The Following Grounds :- 1. Whether On The Facts & Circumstances Of The Case & In Law The Ld. Cit(A) Erred In Deleting The Additions To The Tune Of Rs 17,75,988/- Made U/S 68 Of The I.T. Act Made On Account Of Unaccounted Transactions, Ignoring The Evidences Brought On Record By The Assessing Officer To Establish That The Genuineness Of The Transaction & Creditworthiness Could Not Be Satisfactorily Proved In This Case?

For Appellant: Shri Siddharth Kejriwal, ARFor Respondent: Ms. Madhumita Sas, Addl.CIT
Section 147Section 148Section 68

recorded for escapement of income of Rs. 71,51,500/- (sales minus purchases). A number of case laws are quoted on the issue of borrowed satisfaction claiming that re-assessment done by AO merely on the information of Investigation Wing is not good in law. 6.2 The re-opening ... escapement of income was Rs. 71,51,500/- (sales minus 5 purchases). Thus, the ld. CIT(A) quashed the assessment based on the borrowed satisfaction. Even on merit, the ld. CIT(A) in para 6.3 has noted that no basis of making addition of Rs.17,75,988/- was given

ACIT, Circlle-34, Kolkata vs. Subhas Kumar Kedia, Kolkata

In the result, appeal of the revenue is dismissed

ITA 1677/KOL/2024[2016-17]Status: DisposedITAT Kolkata17 Apr 2025AY 2016-17

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyआयकर अपील सं/Ita No.1677/Kol/2024 (नििाारण वर्ा / Assessment Year : 2016-2017) Acit, Circle-34, Kolkata Vs Subhas Kumar Kedia, 41, N.S.Road, Kolkata Pan No. :Afnpk 9669 M (अपीलार्थी /Appellant) (प्रत्यर्थी / Respondent) .. नििााररती की ओर से /Assessee By : Ms. Shreya Loyalka, Ar राजस्व की ओर से /Revenue By : Shri P.N.Barnwal, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 21/01/2025 घोषणा की तारीख/Date Of Pronouncement : 17/04/2025 आदेश / O R D E R Per Rajesh Kumar, Am : This Is An Appeal Filed By The Revenue Against The Order Dated 05.06.2024, Passed By The Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, For The Assessment Year 2016-2017, On The Following Grounds Of Appeal :- I) That On The Facts & In The Circumstances Of The Case, The Ld. Cit(Appeals), Nfac, Delhi, Erred In Quashing The Order U/S.148A(D) & All Subsequent Proceedings. Ii) That On The Facts & Circumstances Of The Case, The Ld. Cit(Appeals), Nfac, Delhi, Failed To Acknowledge The Fact That The Assesse Had Not Expressed Any Grievance Against The Validity Of Order U/S 148A(D) By Moving Any Writ Petition Which Should Have Been Done In Case Of Any Grievance After Getting The Sald Order U/S.148A(D). Iii) That On The Facts & Circumstances Of The Case, The Ld. Cit(Appeals), Nfac, Delhi, Erred In Quashing The Order When The Ld. Cit(A) Has No Jurisdiction To Deal With The Question Whether The 148A(D) Order Was Passed Validly Or Properly As An Order U/S.148A(D) Is Not An Appealable Order Before Ld. Cit(A) As Per Section 246A.

For Appellant: Ms. Shreya Loyalka, ARFor Respondent: Shri P.N.Barnwal, CIT-DR
Section 148Section 148ASection 149Section 151Section 246ASection 3Section 69A

basis of which department sought to make the addition. It is completely unjustified and uncalled for and in violation of principles of natural justice. Borrowed satisfaction of investigation wing and non application of own mind 6. After hearing the rival contentions of the parties and perusing the material available ... relied upon by the department, thereby causing the miscarriage of justice. Besides, the reopening of the assessment has been made on the basis of borrowed satisfaction of investigation wing without any independent application of mind by the AO as there was no enquiry or application of mind

Indo Pacific Finlease Ltd, Chandigarh vs. PCIT- Chandigarh 1, Chandigarh

In the result, both the appeals are filed by the

ITA 449/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh16 Apr 2025AY 2015-16

Bench: Shrilaliet Kumar & Shri Krinwant Sahayआयकर अपील सं . / I.T.A. Nos.448 & 449/Chd/2024 निर्धारणवर्ष / Assessment Years: 2014-15 & 2015-16

For Appellant: Sh. Ashok Goel, C.AFor Respondent: Sh.Rohit Sharma, CIT-D.R
Section 147Section 148Section 203(1)Section 263

been recorded on Incorrect facts as no loan has been received from Sh. Joginder Pal Gupta c) The reasons have been recorded on borrowed satisfaction d) Objection to reason were filed on 01.01.2022 there is по disposal order before assessment order. e) The notice is based on information ... Ld.Counsel for the assessee, it is the AO of the assessee whose satisfaction is crucial for reopening and it cannot be a borrowed satisfaction. Also, as pointed out to us by the Ld.Counsel for the assessee and not controverted by the DR, the jurisdiction of the AO, NMS, lay with

Indo Pacific Finlease Ltd, Chandigarh vs. PCIT Chandigarh 1, Chandigarh

In the result, both the appeals are filed by the

ITA 448/CHANDI/2024[2014-15]Status: DisposedITAT Chandigarh16 Apr 2025AY 2014-15

Bench: Shrilaliet Kumar & Shri Krinwant Sahayआयकर अपील सं . / I.T.A. Nos.448 & 449/Chd/2024 निर्धारणवर्ष / Assessment Years: 2014-15 & 2015-16 Vs Pcitchandigarh 1, Chandigarh Indo Pacific Finlease Ltd., Sco-98-99, Sector 34 Sub City Centre, Chandigarh 160002 स्थायीलेखासं./Panno. Aaaci2176E अपीलार्थी/Appellant प्रत्यर्थी/Respondent Assessee By : Sh. Ashok Goel, C.A. Revenue By : Sh.Rohit Sharma, Cit-D.R. Date Of Hearing :19.03.2025 Date Of Pronouncement ;16/04/2025 Physical Hearing Order Per Laliet Kumar, J.M.: Both The Appeals Are Being Filed By The Assessee, Feeling Aggrieved By The Order Passed By The Ld. Pr. Commissioner Of Income Tax, Chandigarh-1 Dated 28.03.2024& 23.03.2024 U/S 263 For The Assessment Years: 2014-15& 2015-16. 2. The Assessee Has Raised The Common Grounds Of Appeal In Ita Nos.448 & 449/Chd/2024 As Under:

For Appellant: Sh. Ashok Goel, C.AFor Respondent: Sh.Rohit Sharma, CIT-D.R
Section 147Section 148Section 203(1)Section 263

been recorded on Incorrect facts as no loan has been received from Sh. Joginder Pal Gupta c) The reasons have been recorded on borrowed satisfaction d) Objection to reason were filed on 01.01.2022 there is no disposal order before assessment order. e) The notice is based on information ... been recorded on Incorrect facts as no loan has been received from Sh. Joginder Pal Gupta c) The reasons have been recorded on borrowed satisfaction d) Objection to reason were filed on 01.01.2022 there is no disposal order before assessment order. e) The notice is based on information