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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

ITO 5(2)(1) Mumbai, Mumbai vs. Mokxa Diamond Private Limited, Surat

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

ITA 2208/MUM/2024[2017-18]Status: DisposedITAT Mumbai27 Jan 2026AY 2017-18

Bench: Hon’Ble Shri Sandeep Gosain& Shri Prabhash Shankarito – 5(2)(1) Vs. Moxa Diamond Pvt Ltd Aayakar Bhavan, Mk 72/B-12, Tikam House, Road, New Marine Lines, Jss Road, Opera House, Mumbai – 400020 Girgaon S.O, Mumbai – 400004. Pan/Gir No. Aagcm1959H (Applicant) (Respondent) Moxa Diamond Pvt Ltd Vs. Ito – 5(2)(1) 72/B-12, Tikam House, Jss Aayakar Bhavan, Mk Road, Opera House, Girgaon Road, New Marine S.O, Mumbai – 400004. Lines, Mumbai – 400020 Pan/Gir No. Aagcm1959H (Applicant) (Respondent) Assessee By Shri Bharat Kumar Revenue By Shri Surendra Mohan, Sr. Dr Date Of Hearing 10.12.2025 Date Of Pronouncement 27.01.2026 आदेश / Order Per Sandeep Gosain, Jm: The Present Appeals Have Been Filed By The Revenue As Well As Assessee Challenging The Impugned Order Dt. 26.02.2024

Section 143(3)Section 148Section 153CSection 250Section 68

erred in confirming reopening of the case whereas Ld. A.O. reopened the case on the basis of vague reasons, borrowed satisfaction and non- application of Mind. 4. On the facts and circumstances of the case in law, Ld A.O. erred in reopening of the case u/s 148 and overridden specific

Gupta Builder and Developers, Mumbai vs. ACIT Central Circle 4(3), Mumbai

In the result, ground no. 3 of the assessee‟s appeal is allowed

ITA 70/MUM/2025[2017-18]Status: DisposedITAT Mumbai23 Jan 2026AY 2017-18

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm M/S. Gupta Builders & Developers Asst. Commissioner Of Income 1201 & 1202, Bhumiraj Costarica, Tax, Central Circle 4(3), Mumbai Plot No. 1 & 2, Near Moraj Circle, Vs. Sector 18, Sanpada, Navi Mumbai – 400705. Pan/Gir No. Aajfg3066H (Appellant) : (Respondent)

For Respondent: Shri Asif Karmali SR DR
Section 143(3)Section 148Section 148ASection 151Section 250

record any tangible material. 2 M/s. Gupta Builders and Developers 9. BECAUSE, the AO has erred in reopening of assessment on the basis of "borrowed satisfaction" of information from survey party without any independent corroboratic. or application of mind and preliminary enquiries. 10. BECAUSE, there is no failure

Jamnadas Virji Shares and Stock Brokers Private Limited, Mumbai vs. Deputy Commissioner of Income Tax 4(3)(1), Mumbai

In the result, all the appeals filed by the assessee are

ITA 8364/MUM/2025[2017-18]Status: DisposedITAT Mumbai22 Jan 2026AY 2017-18

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokar

Section 10(34)Section 133ASection 139(1)Section 143(1)Section 143(3)Section 144BSection 147Section 148Section 250Section 37(1)

Profit and Loss Account as business promotion expenses. The assessee also challenged the validity of reopening on the ground that it was based on borrowed satisfaction, without independent application of mind, and that the statement of the proprietor of 4 ITA No. 8361 to 8364/Mum/2025 Jamnadas Virji Shares & Stock Brokers ... appellant submits that the reopening under section 147 was without jurisdiction, as the AO resorted to section 147 on the basis of borrowed satisfaction. 6. The learned CIT(A) / NFAC erred in ignoring the retraction issued by the sole proprietor of M/s Swastik Corporation, and which was relied

Jamnadas Virji Shares and Stock Brokers Private Limited, Mumbai vs. Deputy Commissioner of Income Tax 4(3)(1), Mumbai

In the result, all the appeals filed by the assessee are

ITA 8363/MUM/2025[2016-17]Status: DisposedITAT Mumbai22 Jan 2026AY 2016-17

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokar

Section 10(34)Section 133ASection 139(1)Section 143(1)Section 143(3)Section 144BSection 147Section 148Section 250Section 37(1)

Profit and Loss Account as business promotion expenses. The assessee also challenged the validity of reopening on the ground that it was based on borrowed satisfaction, without independent application of mind, and that the statement of the proprietor of 4 ITA No. 8361 to 8364/Mum/2025 Jamnadas Virji Shares & Stock Brokers ... appellant submits that the reopening under section 147 was without jurisdiction, as the AO resorted to section 147 on the basis of borrowed satisfaction. 6. The learned CIT(A) / NFAC erred in ignoring the retraction issued by the sole proprietor of M/s Swastik Corporation, and which was relied

Jamnadas Virji Shares and Stock Brokers Pvt Ltd, Mumbai vs. Deputy Commissioner of Income Tax 4(3)(1), Mumbai

In the result, all the appeals filed by the assessee are

ITA 8362/MUM/2025[2015-16]Status: DisposedITAT Mumbai22 Jan 2026AY 2015-16

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokar

Section 10(34)Section 133ASection 139(1)Section 143(1)Section 143(3)Section 144BSection 147Section 148Section 250Section 37(1)

Profit and Loss Account as business promotion expenses. The assessee also challenged the validity of reopening on the ground that it was based on borrowed satisfaction, without independent application of mind, and that the statement of the proprietor of 4 ITA No. 8361 to 8364/Mum/2025 Jamnadas Virji Shares & Stock Brokers ... appellant submits that the reopening under section 147 was without jurisdiction, as the AO resorted to section 147 on the basis of borrowed satisfaction. 6. The learned CIT(A) / NFAC erred in ignoring the retraction issued by the sole proprietor of M/s Swastik Corporation, and which was relied

Jamnadas Virji Shares and Stock Brokers Private Limited, Mumbai vs. DCIT, 4(3)(1), Mumbai

In the result, all the appeals filed by the assessee are

ITA 8361/MUM/2025[2014-15]Status: DisposedITAT Mumbai22 Jan 2026AY 2014-15

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokar

Section 10(34)Section 133ASection 139(1)Section 143(1)Section 143(3)Section 144BSection 147Section 148Section 250Section 37(1)

Profit and Loss Account as business promotion expenses. The assessee also challenged the validity of reopening on the ground that it was based on borrowed satisfaction, without independent application of mind, and that the statement of the proprietor of 4 ITA No. 8361 to 8364/Mum/2025 Jamnadas Virji Shares & Stock Brokers ... appellant submits that the reopening under section 147 was without jurisdiction, as the AO resorted to section 147 on the basis of borrowed satisfaction. 6. The learned CIT(A) / NFAC erred in ignoring the retraction issued by the sole proprietor of M/s Swastik Corporation, and which was relied

Arvind Bhaguji Kangane, Mumbai vs. Dy. Commissioner of Income Tax, Circle-27(1), Mumbai

In the result, ground no. 2 and 3 of appeal are

ITA 4158/MUM/2025[2016-17]Status: DisposedITAT Mumbai22 Jan 2026AY 2016-17

Bench: Shri Pawan Singh & Ms. Padmavathy S(Physical Hearing) Arvind Bhanguji Kangane Dcit, Circle – 27(1), Mumbai Shreyas Building, 11Th Road, Plot No. 4Th Floor, Tower No. 6, Vashi Vs 553, Flat No. 901, 9Th Floor, Opp. Railway Station Building, Navi Heritage Pride Building, Chembur, Mumbai – 400703. Mumbai – 400026. [Pan: Afypk1856R] Appellant / Assessee Respondent / Revenue

Section 10(38)Section 143(1)Section 144BSection 147Section 148Section 151ASection 254(1)Section 68

erred in confirming the validity of notice u/s 148 issued in mechanical manner, in absence of new tangible material and on the basis of borrowed satisfaction and without having reason to believe of escapement of income; 2.0 On facts and circumstances of the case ... validity of reopening the assessee submitted that objection of assessee was rejected mechanically. There was no sufficient tangible material. The reopening was based on borrowed satisfaction. 5. The ld. CIT(A) on considering the submission of assessee and the assessment order upheld that validity of reopening by taking view that

Sandhya Singh, Rohit Nagar, Bhopal vs. ITO 2(3) Bhopal, Aaykar Bhawan, Bhopal

In the result, the appeal is allowed for statistical purposes

ITA 584/IND/2025[2013-2014]Status: DisposedITAT Indore21 Jan 2026AY 2013-2014

Bench: Shri Siddhartha Nautiyal & Shri Bhagirath Mal Biyani

For Appellant: Adv. Sh. Gagan TiwariFor Respondent: Date of Hearing
Section 115BSection 143(1)Section 147Section 148Section 69A

believe that income had escaped assessment. It was submitted that the reasons recorded for reopening are based purely on third-party information and borrowed satisfaction, without any independent inquiry, verification, or analysis by the Assessing Officer. The learned Counsel submitted that such mechanical initiation of reassessment proceedings, without establishing

Vimal Alloys Private Limited, Mandi Gobindgarh, Punjab vs. Jao the Deputy Commissioner of Income Tax Circle, Patiala, Punjab

ITA 890/CHANDI/2025[2016-2017]Status: DisposedITAT Chandigarh21 Jan 2026AY 2016-2017

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Sudhir Sehgal, Advocate and Shri Vipen Sethi, AdvocateFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR
Section 143(1)Section 147Section 148Section 151Section 69A

erred in confirming the action of the Ld. AO in passing the order u/s 147/143(3) without appreciating that the reasons are based on borrowed satisfaction and there is no independent application of mind by the Ld. AO and nor any enquiry have been made before issue of notice ... suffers from gross violation of the principles of natural justice. 7.4 The Ld. AR also submitted that the reopening of assessment was based on borrowed satisfaction, as the Assessing Officer merely acted on the information received from the Investigation Wing without any independent application of mind. The reasons recorded

Vikramkumar Kishanlal Mehta, Mahisagar vs. The DCIT, Anand Circle, Anand

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

ITA 313/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad21 Jan 2026AY 2018-19

Bench: Shri Sanjay Garg & Annapurna Guptaआयकर अपील सं /Ita No.313/Ahd/2024 िनधा"रण वष" /Assessment Year : 2018-19 Vikramkumar Kishanlal The Dcit बनाम/ Mehta Anand Circle V/S. C/O. Mahesh Masala Gruh Anand – 388 001 Udhyog 21, Gidc Estate Balasinor Mahisagar – 388 255 "थायी लेखा सं./Pan: Aqhpm 9958 I (अपीलाथ)/ Appellant) (*+ यथ)/ Respondent) Assessee By : Shri Dhinal Shah, Ar Revenue By : Shri Sher Singh, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 18/12/2025 घोषणा की तारीख /Date Of Pronouncement: 21/01/2026 आदेश/O R D E R Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 05/02/2024 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2018-2019. 2. The Assessee, In This Appeal, Has Taken The Following Grounds Of Appeal: Vikramkumar Kishanlal Mehta Vs. Dcit Asst. Year : 2017-19

For Appellant: Shri Dhinal Shah, ARFor Respondent: Shri Sher Singh, CIT-DR
Section 115BSection 147Section 148Section 148ASection 250Section 68Section 69

opened the assessment. He, therefore, has submitted that the re-opening of the assessment has been made by the AO on the basis of borrowed satisfaction of the Investigation Wing (IW). He has submitted that the information received from the IW was factually wrong and, therefore, the reopening

Dona Builders Pvt Ltd, Mumbai vs. DCIT, Circle 1(3)(1), Mumbai

ITA 5375/MUM/2025[2013-14]Status: DisposedITAT Mumbai21 Jan 2026AY 2013-14

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan() Assessment Year: 2009-10 & Assessment Year: 2010-11 & Assessment Year: 2011-12 & Assessment Year: 2012-13 & Assessment Year: 2013-14 Dona Builders Pvt Ltd Dcit, Circle 1(3)(1), Mumbai 108, Shiv Aashish S.V. Road, Aayakar Bhavan, Mumbai- Vs. Andheri West, Mumbai- 400058 400020 Pan No. Aaacd 3116 F Appellant Respondent : Mr. Rajesh Shah Assessee By : Mr. Annavaram Kosuri, Sr-Dr A/W Revenue By Mr. Uma Shankar Prasad, Cit Dr : 06/11/2025 Date Of Hearing Date Of Pronouncement : 21/01/2026 Order Per Bench These Five Appeals By The Assessee Are Directed Against Separate Orders Passed By The Ld. Commissioner Of Income-Tax

For Appellant: Mr. Annavaram Kosuri, SR-DR a/wFor Respondent: Mr. Rajesh Shah
Section 147Section 68

based The learned counsel also submitted that the reopening was based The learned counsel also submitted that the reopening was based on a borrowed satisfaction of the Investigation Wing, without on a borrowed satisfaction of the Investigation Wing, without on a borrowed satisfaction of the Investigation Wing, without independent application ... information received. The formation of belief is received. The formation of belief is not mechanical nor based on not mechanical nor based on borrowed satisfaction, but on an objective appraisal of material borrowed satisfaction, but on an objective appraisal of material borrowed satisfaction, but on an objective appraisal of material

Dona Builders Pvt Ltd, Mumbai vs. DCIT, Circle 1(3)(1), Mumbai

ITA 5374/MUM/2025[2011-12]Status: DisposedITAT Mumbai21 Jan 2026AY 2011-12

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan()

For Respondent: Mr. Rajesh Shah
Section 147Section 250Section 68

absence of any such share application money, thereby granting approval mechanically. The learned counsel also submitted that the reopening was based on a borrowed satisfaction of the Investigation Wing, without independent application of mind by the Assessing Officer. 6.1 Per contra, the learned Departmental Representative supported the orders ... recorded demonstrate independent application of mind by the Assessing Officer to the information received. The formation of belief is not mechanical nor based on borrowed satisfaction, but on an objective appraisal of material linking the assessee with the alleged accommodation entries. The mere fact that one component of the information

Dona Builders Pvt Ltd, Mumbai vs. DCIT, Circle 1(3)(1), Mumbai

ITA 5373/MUM/2025[2012-13]Status: DisposedITAT Mumbai21 Jan 2026AY 2012-13

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan()

For Respondent: Mr. Rajesh Shah
Section 147Section 250Section 68

absence of any such share application money, thereby granting approval mechanically. The learned counsel also submitted that the reopening was based on a borrowed satisfaction of the Investigation Wing, without independent application of mind by the Assessing Officer. 6.1 Per contra, the learned Departmental Representative supported the orders

Dona Builders Pvt Ltd, Mumbai vs. DCIT, Circle 1(3)(1), Mumbai

ITA 5372/MUM/2025[2010-11]Status: DisposedITAT Mumbai21 Jan 2026AY 2010-11

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan()

For Respondent: Mr. Rajesh Shah
Section 147Section 250Section 68

absence of any such share application money, thereby granting approval mechanically. The learned counsel also submitted that the reopening was based on a borrowed satisfaction of the Investigation Wing, without independent application of mind by the Assessing Officer. 6.1 Per contra, the learned Departmental Representative supported the orders

Dona Builders Pvt Ltd, Mumbai vs. DCIT, Circle 1(3)(1), Mumbai

ITA 5371/MUM/2025[2009-10]Status: DisposedITAT Mumbai21 Jan 2026AY 2009-10

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan() Assessment Year: 2009-10 & Assessment Year: 2010-11 & Assessment Year: 2011-12 & Assessment Year: 2012-13 & Assessment Year: 2013-14 Dona Builders Pvt Ltd Dcit, Circle 1(3)(1), Mumbai 108, Shiv Aashish S.V. Road, Aayakar Bhavan, Mumbai- Vs. Andheri West, Mumbai- 400058 400020 Pan No. Aaacd 3116 F Appellant Respondent : Mr. Rajesh Shah Assessee By : Mr. Annavaram Kosuri, Sr-Dr A/W Revenue By Mr. Uma Shankar Prasad, Cit Dr : 06/11/2025 Date Of Hearing Date Of Pronouncement : 21/01/2026 Order Per Bench These Five Appeals By The Assessee Are Directed Against Separate Orders Passed By The Ld. Commissioner Of Income-Tax

For Appellant: Mr. Annavaram Kosuri, SR-DR a/wFor Respondent: Mr. Rajesh Shah
Section 147Section 68

based The learned counsel also submitted that the reopening was based The learned counsel also submitted that the reopening was based on a borrowed satisfaction of the Investigation Wing, without on a borrowed satisfaction of the Investigation Wing, without on a borrowed satisfaction of the Investigation Wing, without independent application ... information received. The formation of belief is received. The formation of belief is not mechanical nor based on not mechanical nor based on borrowed satisfaction, but on an objective appraisal of material borrowed satisfaction, but on an objective appraisal of material borrowed satisfaction, but on an objective appraisal of material

Property Plus Realtores, Delhi vs. Pr CIT Central Delhi-2, Delhi

ITA 3407/DEL/2025[2021-22]Status: DisposedITAT Delhi21 Jan 2026AY 2021-22

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

Section 263

ITA Nos.3406 & 3407/Del/2025 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI “E” BENCH: NEW DELHI BEFORE SHRI YOGESH KUMAR U.S, JUDICIAL

Property Plus Realtors, Delhi vs. Pr, CIT Central Delhi 2, Delhi

In the result, appeal of the assessee is allowed

ITA 3406/DEL/2025[2020-21]Status: DisposedITAT Delhi21 Jan 2026AY 2020-21

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

Section 132Section 143(2)Section 143(3)Section 145(3)Section 263

quashed. Ground No.5 5. Because on fact and in law and the grounds taken and basis adopted the Impugned Order is based on borrowed satisfaction and without application of mind. The impugned order is, therefore, not maintainable. Ground No.6 6. Because on facts and in law the Ld. PCIT grossly ... characterisation of income by invoking power u/s 263 is ultra vires. The Ground No.3 taken by the Appellant ought to be allowed. Ground 5: Borrowed Satisfaction 34. The Ground No.5 taken by the Appellant is as under, Because on fact and in law and the grounds taken and basis adopted

Gautam Chopra, New Delhi vs. DCIT, Jhandewallan Extension

ITA 2567/DEL/2025[2021-2022]Status: DisposedITAT Delhi21 Jan 2026AY 2021-2022

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 132Section 132(4)Section 142(1)Section 143(2)Section 147Section 148Section 151Section 250Section 69C

information received from investigation wing and in absence of any independent application of mind or enquiry, the reopening u/s. 148 is wholly based on borrowed satisfaction and is not sustainable for want of tangible/adverse material. 1.2 That information from investigation wing per se does not constitute tangible material and there

Sri Ram Health Care Private Limited, Baddi vs. Deputy Commissioner of Income Tax, Circle - Parwanoo, Parwanoo

In the result, all the appeal of the Assessee stand allowed for statistical purposes

ITA 850/CHANDI/2025[2010-11]Status: DisposedITAT Chandigarh20 Jan 2026AY 2010-11

Bench: Shri Laliet Kumar & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 850/Chd/2025 "नधा"रण वष" / Assessment Year : 2010-11 Sri Ram Health Care Private The Dcit, Limited, बनाम Circle. 81C/2 Epip Phase I, Parwanoo Vs. Jharmajari, Baddi, Himachal Pradesh 173205 "थायी लेखा सं./ Pan No: Aamcs5840H अपीलाथ"/Appellant ""यथ"/Respondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : Sh. Manoj Kumar, Ca राज"व क" ओर से/ Revenue By : Dr.Ranjit Kaur, Addl. Cit, Sr. Dr

For Appellant: Sh. Manoj Kumar, CAFor Respondent: Dr.Ranjit Kaur, Addl. CIT, Sr. DR
Section 143(2)Section 143(3)Section 147Section 148Section 151(2)Section 68

confirming the validity of notice issued u/s 148, by ignoring that the Id. A.O. has issued notice u/s 148 on the basis of borrowed satisfaction, without applying his own mind as the notice u/s 148 was issued solely on the basis of third party information as stated in the reasons

Krunalkumar Virambhai Desai, Gandhinagar vs. The ITO, Ward-1, Gandhinagar

In the result, the appeal of the assessee is allowed

ITA 1703/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad20 Jan 2026AY 2014-15

Bench: Shri Sddhartha Nautiyal & Shri Narendra Prasad Sinhaassessment Years:2014-15

Section 147Section 234A

property, but there is no mention of the underlying asset. No particulars are specified in the reason, which is found to be based on borrowed satisfaction only. It appears, prima facie, that the proceeding was initiated by the ACB against Shri. Vikrambhai Lilabhai Desai, father of the assessee