“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

Laljibhai Parshottambhai Gaudani, Ahmedabad vs. The Dy.CIT, Circle-3(1)(1), Ahemdabad

ITA 1238/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad13 Jan 2026AY 2012-13

Bench: Ms. Suchitra Raghunath Kamble & Shri Narendra Prasad Sinhaassessment Year:2012-13

Section 143Section 143(3)Section 148Section 2(47)(v)Section 27(1)(c)Section 50CSection 50C(5)Section 53A

explanations, and supporting documentary evidence. Hence, the assessment lacks proper legal and factual basis. 4. Speaking Order: The learned AO has issued notice on borrowed satisfaction to believe that income has escaped assessment under the Act and further completed assessment under section 143 of the Act, without refuting to facts

Deputy Commissioner of Income Tax, Kolkata vs. Vedanta Resources Private Limited, Kolkata

In the result, the Cross Objection of the assessee is allowed and

ITA 1845/KOL/2025[2016-17]Status: DisposedITAT Kolkata13 Jan 2026AY 2016-17

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Sunil Surana, ARFor Respondent: Shri Sanat Kumar Raha, DR

Section 133ASection 143(2)Section 147Section 148

done any enquiry to bring out any tangible materials and at can best be treated as a patent example of borrowed satisfaction by the AO. 3.2. After hearing both the sides and perusing the materials on records we find that the AO re-opened the assessment after receipt of information ... above reasons revealed that the Id. AO has recorded very cryptic reasons which are vague, scanty and at best can be considered as borrowed satisfaction of the Id. AO as AO has not recorded any satisfaction on the information received. Therefore, there is no live link between the information

Abhishek Jayketu Joshi, Mumbai vs. Ac Cir-42(2)(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 5775/MUM/2025[2019-20]Status: DisposedITAT Mumbai13 Jan 2026AY 2019-20

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokarabhishek Jayketu Joshi Ac Cir-42(2)(1), C-73, Venus Society, R. G. Kautilya Bhavan, Thadani Marg, Worli Sea Vs. Mumbai-400 051 Face, Mumbai-400 018 Pan/Gir No. Ackpj8583H (Applicant) (Respondent) Assessee By Shri M. M. Golvala, Ld. Ar Revenue By Shri Surendra Mohan, Ld. Dr Date Of Hearing 07.01.2026 Date Of Pronouncement 13.01.2026

Section 132Section 132(4)Section 139(1)Section 139(5)Section 143(1)Section 144BSection 147Section 148Section 148ASection 250

relying on section 148 of the Act when the jurisdictional conditions were not satisfied. 2. The AO erred in resorting to Section 147 on “borrowed satisfaction”. 3. Both the lower authorities failed to consider that jurisdiction u/s.147 was wrongly assumed by the Jurisdictional Assessing Officer (JAO) issuing a notice u/s.148

DCIT(CC)-8(3), Mumbai vs. Shapoorji Pallonji and Company Private Limited, Mumbai

In the result, the cross-objection of the assessee is partly

ITA 2831/MUM/2025[2014-15]Status: DisposedITAT Mumbai12 Jan 2026AY 2014-15

Bench: Shri Om Prakash Kant ()

Section 115JSection 143(3)Section 147Section 148Section 14A

provisions of Section 151 of the Act and thus leading to entire reassessment proceedings bad in law; Reopening assessment on the basis of borrowed satisfaction: 4. ought to have appreciated that the officer recording the reasons for re-opening and the officer issuing the notice under section ... different and therefore, the impugned proceedings conducted on borrowed satisfaction are bad-in-law and liable to be quashed; 5. erred in reopening the assessment proceedings and passing order under section 147 of the Act solely on the basis of the 4 Shapoorji Pallaonji And Company

Rajkamal Agro Industries, Deesa vs. ITO, Ward 1, Palanpur

In the result, the appeal of the assessee stands allowed

ITA 1853/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad09 Jan 2026AY 2015-16

Bench: Shri Sanjay Gargआयकर अपील सं /Ita No.1853/Ahd/2025 िनधा"रण वष" /Assessment Year : 2015-16 Rajkamal Agro Industries The Ito बनाम/ Deesa Palanpur Highway Ward-I V/S. At Rasna, Deesa – 385 535 Palanpur 385 001 (Gujarat) "थायी लेखा सं./Pan: Aaifr 7263 C (अपीलाथ$/ Appellant) (%& यथ$/ Respondent) Assessee By : Shri Chetan Agarwal, Ar Revenue By : Smt. Mamta Singh, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 08/01/2026 घोषणा की तारीख /Date Of Pronouncement: 09/01/2026 आदेश/O R D E R 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 04/09/2025 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2015-2016. 2. The Assessee, In This Appeal, Has Taken The Following Grounds Of Appeal:

For Appellant: Shri Chetan Agarwal, ARFor Respondent: Smt. Mamta Singh, Sr.DR

Section 147Section 250

vague reasons Rajkamal Agro Industries vs. ITO Asst. Year : 2015-16 2 recorded for re-opening without independent application of mind and on borrowed satisfaction. 3. The Ld. CIT(A) erred in law as well as on fact in upholding an addition of Rs. 30,31,590/- made ... reopening of the assessment, on this issue, has also been made by the AO without application of mind and merely on the basis of borrowed satisfaction, acting blindly on the objections of the audit party. The Ld. Rajkamal Agro Industries vs. ITO Asst. Year : 2015-16 4 Counsel has relied

Rakesh Divedi, Delhi vs. Income Tax Officer, Ward 43(6), Delhi

In the result, appeal of the Assessee is allowed

ITA 3290/DEL/2025[2009-10]Status: DisposedITAT Delhi09 Jan 2026AY 2009-10

Bench: Shri Sudhir Kumar & Shri Manish Agarwalrakesh Divedi, Income Tax Officer, 87, Triveni Apartments, Ward-43(6), Delhi. Pitampura, New Delhi - Vs. 110034. Pan-Apcpd9179A (Appellant) (Respondent) Shri Pranshu Singhal, Ca Assessee By & Ms. Mansi Jain, Adv. Department By Ms. Ankush Kalra, Sr. Dr Date Of Hearing 30/10/2025 Date Of Pronouncement 09/01/2026 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (‘Ld. Cit(A)’ In Short) Dated 07.03.2025 In Appeal No.40/10204/2018-19 Arising Out Of The Order Passed By The Income Tax Officer, Ward-40(3) U/S 143(3) Of The Act (‘The Act’ For Short) Dated 20.12.2016 For Assessment Year 2009-10. 2. Brief Facts Of The Case Are That Assessee Is An Individual & Proprietor Of M/S Triambkay Gauri Impex. The Information Was Received By The Ao From Investigation Wing That There Were Cash Deposits In The Bank Account Of The Assesse With Icici Bank, However, Income Of The Assessee & Gross Receipt Has Not Rakesh Divedi Vs. Income Tax Officer Commensurate With The Cash So Deposited, Therefore, After Recording The Reason U/S 147, Notice U/S 148 Was Issued On 31.03.2016 After Obtaining Statutory Approval From The Pcit. Thereafter, Assessment Was Completed Vide Order Dated 20.12.2016 Wherein Total Addition Of Rs. 5,20,88,345/- Was Made U/S 68 Of The Act For Cash Deposited In The Bank Accounts By Holding The Same As Unexplained Cash Credits. 3. Against The Said Order, Assessee Has Filed An Appeal Before Ld. Cit(A) Who Vide Impugned Order Has Partly Allowed The Appeal Of The Assessee & Directed The Ao To Make Addition Of Peak Credit Of The Total Deposits In The Bank Accounts.

Section 143(2)Section 143(3)Section 147Section 148Section 151Section 68

quashed as the same has been reopened on the basis of the reasons which are vague and has been recorded only on borrowed satisfaction. 4. On the facts and circumstances of the case, the Ld. CIT(A) has erred in confirming the order of the AO despite the fact that ... validity of reopening of the assessment as the approval given by ld. PCIT is mechanical approval and reasons recorded are vague and based on borrowed satisfaction. 10. Heard both the parties and perused the materials available on record. In the instant case, ld. PCIT has granted the approval

Gyan Enterprises Private Limited, New Delhi vs. ACIT Circle 10(2), New Delhi

ITA 2401/DEL/2025[2012-2013]Status: DisposedITAT Delhi09 Jan 2026AY 2012-2013

Bench: Shri S Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Sh. Chandan Agarwal, CAFor Respondent: Sh. Ajay Kumar Arora, Sr. DR

Section 143(2)Section 143(3)Section 147Section 148

Page 1 ITA No.2401/Del/2025 Gyan Enterprises Pvt. Ltd. (AY: 2012-13) IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, DELHI

Ktm Impex Private Limited, Panipat vs. ITO, Panipat

In the result, appeal filed by the assessee is allowed

ITA 2377/DEL/2025[2019-20]Status: DisposedITAT Delhi09 Jan 2026AY 2019-20

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Amit Kaushik, AdvocateFor Respondent: Shri Ajay Kumar Arora, Sr. DR

Section 142(1)Section 143(2)Section 143(3)Section 147Section 148

generalized third- party information without any independent application of mind or tangible material relating specifically to the Appellant. Relied on. 2. Reassessment based on borrowed satisfaction and constitutes mere change of opinion The AO acted mechanically based on third-party statements and no inquiry was conducted to corroborate allegations with ... third-party information without any independent application of mind or tangible material relating specifically to the assessee. He further submitted that reassessment based on borrowed satisfaction and constitutes mere change of opinion, the AO acted mechanically based on third-party statements and no inquiry was conducted to corroborate allegations with

Anant Bhalchandra Hendre, Mahad vs. Income-Tax Officer, Panvel

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

ITA 597/PUN/2025[2017-18]Status: DisposedITAT Pune08 Jan 2026AY 2017-18

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Anup ShahaFor Respondent: Shri Vidya Ratna Kishore

Section 107Section 142(1)Section 147Section 148Section 148ASection 151Section 69A

case and in law, the Ld. CIT(A) erred in confirming considering the facts that the case has been reopened on merely on the borrowed satisfaction and addition is made on presumptions and surmises. Accordingly, the addition so made be deleted and just & due relied be given to the appellant

Colen Chemical Pvt. Ltd., Jamshedpur vs. ITO, Ward 1(1), Jamshedpur

In the result, both appeals of the assessee are allowed

ITA 167/RAN/2025[2014-15]Status: DisposedITAT Ranchi07 Jan 2026AY 2014-15

Bench: Shri George Mathan, Jm & Shri Ratnesh Nandan Sahay, Am आयकर अपील सं./Ita No.165 & 167/Ran/2025 (निि ारण वर्ा / Assessment Year :2013-2014 & 2014-2015) Colen Chemical Pvt. Ltd, Vs. Ito Ward-1(1), Jamshedpur 1St Floor, Room No.9, Tiwary Bechar Complex, Main Rd. Bistupur, Jamshedpur-831001 स्थायी लेखा सं./Pan No. : Aabcc 3978 K (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) निर्ाारिती की ओर से /Assessee By : Shri Sunil Surana, Ar राजस्व की ओर से /Revenue By : Shri Ram Chandra Marndi, Sr.Dr सुनवाई की तारीख / Date Of Hearing : 07/01/2026 घोषणा की तारीख/Date Of Pronouncement : 07/01/2026 आदेश / O R D E R Per Bench : These Two Appeals Are Filed By The Assessee Against The Separate Orders Passed By The Ld.Cit(A), National Faceless Appeal Centre (Nfac), Delhi, Both Dated 31.03.2025 For The Assessment Year 2013-2014. 2. It Was Submitted By The Ld.Ar That For The Assessment Year 2013- 2014 The Original Assessment Came To Be Completed U/S.143(3) Of The Act On 29/01/2016 & For The Assessment Year 2014-2015 The Original Assessment Came To Be Completed U/S.143(3) Of The Act On 29.12.2016. Notice U/S.148 Of The Act For A.Y.2013-2014 Came To Be Issued On 28.03.2018 & For A.Y.2014-2015 The Notice Was Issued On 24.06.2019. The Ld. Ar Drew Our Attention To Reason Recorded To Reopening For The Assessment Year 2013-2014 At Pages 47 To 51 Of The Paper Book Which Reads As Follows:-

For Appellant: Shri Sunil Surana, ARFor Respondent: Shri Ram Chandra Marndi, Sr.DR

Section 143(3)Section 147Section 148

case of P.L.Goenka HUF, passed in ITAT/241/2024 IA No:GA/2/2024, dated 06.05.2025. It was submission that even if the reason recorded are borrowed satisfaction, still it should be held that the reason are valid. It was the submission that the reopening of the assessment is liable to be upheld

Colen Chemical Pvt. Ltd., Jamshedpur vs. ITO, Ward 1(1), Jamshedpur

In the result, both appeals of the assessee are allowed

ITA 165/RAN/2025[2013-14]Status: DisposedITAT Ranchi07 Jan 2026AY 2013-14

For Appellant: Shri Sunil Surana, ARFor Respondent: Shri Ram Chandra Marndi, Sr.DR

Section 143(3)Section 147Section 148

Kaishar Interiors Private Limtied, Mumbai vs. Deputy Commissioner of Income Tax Circle 4(2)(2), Mumbai

Accordingly Ground No.16 raised by the Assessee is allowed

ITA 5665/MUM/2025[2010-11]Status: DisposedITAT Mumbai07 Jan 2026AY 2010-11

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI PRABHASH SHANKAR (Accountant Member)

For Appellant: Shri Dinesh Kukreja &For Respondent: Shri Hemanshu Joshi

Section 143(3)Section 147Section 148Section 14A

issuing notice u/s 148 of the Act dated 18.03.2015 merely relying on lists shared by the Sales Tax Department without independent enquiry, constituting borrowed satisfaction. 5. On the facts and circumstances of the case and in law, the Ld AO erred in issuing notice u/s 148 of the Act dated

M/S Jhs Svendgaard Laboratories Ltd., New Delhi vs. DCIT CC-31, New Delhi

In the result, Appeal of the Assessee is allowed

ITA 3454/DEL/2025[2018-19]Status: DisposedITAT Delhi07 Jan 2026AY 2018-19

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.M/S Jhs Svendgaard Vs. Dcit Laboratories Ltd. B1/E-23, Central Circle-31, New Mohan Cooperative Delhi Tuhglakabad, Badarpur, New Delhi New Delhi Pan: Aabcj5766G Appellant Respondent Assessee By Sh. Gaurav Jain, Adv & Sh. Tarun Chanana, Adv Revenue By Ms.Amisha S. Gupt, Cit (Dr) Date Of Hearing 09/10/2025 Date Of Pronouncement 07/01/2026 Order Per Yogesh Kumar, U.S. Jm: The Present Appeal Is Filed By The Assessee Against The Order Of The Commissioner Of Income Tax (Appeals)-30, New Delhi [‘Ld. Cit(A)’

Section 147Section 148Section 151ASection 37

fresh tangible material or valid "information" as required under section 148 and Explanation 1 thereto, as the entire reopening was based on a mere borrowed satisfaction and mechanical reproduction of findings of the Investigation Wing without independent application of mind by the Assessing Officer (AO). 2 M/S JHS Sevendgaard Laborotories ... pressed. 6. The Ld. Assessee's Representative arguing on Ground No. 2 & 3 submitted that, the case of the Assessee was reopened based on borrowed satisfaction without any direct or tangible nexus to the case of the Assessee and there was no live and rational nexus between information received

Bholenath Foods Limited, New Delhi vs. Deputy Commissioner of Income Tax, Circle- 4(2), New Delhi

The appeal of the assessee is disposed of in above terms

ITA 5777/DEL/2024[2012-13]Status: DisposedITAT Delhi07 Jan 2026AY 2012-13

Bench: Shri Raj Kumar Chauhan & Shri Manish Agarwalassessment Year : 2012-13 Bholenath Foods Limited, Vs. Income Tax Officer, Shop No.208, Ward 47(1), Bldg. No.2612/13, Naya Bazar, New Delhi. Delhi – 110 006. Pan: Aabcb3842P

For Appellant: Shri Shivam Yadav, Advocate &For Respondent: Shri Ajay Kumar Arora, Sr. DR

Section 133ASection 142(1)Section 143(2)Section 147Section 148Section 250Section 68

independent application of mind and reasons have been recorded in a routine manner and also vague in nature. The same amounts to 'borrowed satisfaction' which is not permitted in law. 9. That, on the facts and circumstances of the case and in law, AO/NFAC has erred in making addition

Naveen Singh, Jamshedpur vs. Deputy Commissioner of Income Tax, Circle - 1, Jamshedpur

In the result, the appeal of the assessee is allowed

ITA 413/RAN/2024[2017-18]Status: DisposedITAT Ranchi06 Jan 2026AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.413/Ran/2024 Assessment Year: 2017-18 Naveen Singh………...…………….…….…............................……….……Appellant M-9 Old, Adityapur Jamshedpur, Jharkhand- 831013. [Pan: Adkps4229A] Vs. Dcit, Circle-1, Jamshedpur.….....…..…..….........……........……...…..…..Respondent Appearances By: Shri P. S. Paul, Ca, Appeared On Behalf Of The Appellant. Shri Sumit Dasgupta, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 18, 2025 Date Of Pronouncing The Order : January 06, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Nfac, Delhi (Hereinafter Referred To As “Cit(A)”) Dated 12.09.2024 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”). 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income For Assessment Year 2017–18 Declaring A Total Income Of ₹43,99,340/- Under Section 139(1) Of The Act. The Return Was Processed Under Section 143(1) Accepting The Income As Declared. Subsequently, The Ao Issued A Notice Under Section 148 Of The Act After Recording Reasons & Obtaining Sanction From The Competent Authority. The Assessee Did Not Respond To The Notice Under Section 148. Thereafter, Multiple Notices Under Section 142(1) Were Issued, Including Final Opportunity Notices, Which Were Duly Served But Remained Unanswered.

Section 139(1)Section 142(1)Section 143(1)Section 144Section 147Section 148Section 250Section 56(2)(x)

three joint purchasers, and the entire difference was wrongly added in the hands of the assessee alone. Hence, the reopening is based on borrowed satisfaction and is bad in law. I.T.A. No.413/Ran/2024 Naveen Singh 5. On merits, the AR submitted that the property consists of leasehold land ... failed to examine the nature of property (leasehold), the number of purchasers (three), the correctness of stamp duty valuation. Such reopening amounts to borrowed satisfaction, which is impermissible in law. From the reference made to the reasons to believe recorded by the Ld. AO and the observations noted

Jigna Ashutosh Bhatt, Mumbai vs. Income Tax Officer Ward 33(2)(1), Mumbai

In the result the appeal of the assessee is partly allowed on merits

ITA 3639/MUM/2025[2011-12]Status: HeardITAT Mumbai06 Jan 2026AY 2011-12

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokarito Ward-32(2)(1) Jigna Ashutosh Bhatt Kautilya Bhavan, I-1434, Govardhan Nagar Bandra Kurla Bldg. No. 4, Opp. Poinsur Vs. Complex, Bandra (E), Gymkhana, Kandivali Mumbai-400 051 (West), Mumbai-400 067 Pan/Gir No. Aiypb4411G (Applicant) (Respondent) Assessee By Shri Ketan L. Vajani, Ld. Ar Revenue By Shri Aditya Rai, Ld. Dr Date Of Hearing 05.01.2026 Date Of Pronouncement 06.01.2026

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

assessee challenged the validity of the reassessment proceedings initiated under section 147 of the Act, contending that the reopening was based on borrowed satisfaction from the Investigation Wing and in the absence of any income escaping assessment.The addition 4 Jigna Ashutosh Bhatt of Rs. 39,00,000/- made under section ... case is not valid for the following reasons: i. That the reassessment in her case had been initiated merely on the basis of the borrowed satisfaction from the Investigation wing of the department, even without bothering to check the statement recorded by the investigation wing. ii. That without prejudice

Pari Anil Gandhi, Rajkot vs. Income Tax Officer, Ward - 2(1)(1), Rajkot

In the result, both the assessee’s appeals are allowed for statistical purpose

ITA 897/RJT/2024[2013-14]Status: DisposedITAT Rajkot05 Jan 2026AY 2013-14

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 896 & 897/Rjt/2024 िनधा"रणवष" / Assessment Year: (2013-14) (Hybrid Hearing) Pari Anil Gandhi Vs. Income Tax Officer, Ward-2(1)(1), C-702 Sadguru Vatika, Airport Road, 2- Aayakar Bhavan Race Course Ring Maruti Nagar, Rajkot - 360001 Road, Rajkot - 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Bahpg7804E (Appellant) (Respondent) Appellant By : Shri D. M. Rindani, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav Ld. Sr. Dr Date Of Hearing : 09 / 10 /2025 Date Of Pronouncement : 05 / 01 /2026 आदेश/Order Per Dinesh Mohan Sinha, Jm; Captioned Two Appeals Filed By The Assessee, Pertaining To Assessment Year 2013-14, Is Directed Against Order Passed Under Section 250 Of The Income Tax Act, 1961 By National Faceless Appeal Centre (Nfac), Delhi/Commissioner Of Income Tax (Appeals), Dated 22/11/2024, Which In Turn Arises Out Of An Order Passed By The Assessing Officer U/S 147 Read With Section 144B Of The I.T. Act, On Dated 28/03/2022. 2. Since, The Issues Involved All These Appeals Are Common & Identical; Therefore, These Appeals Have Been Heard Together & A Consolidated Order Are Being Passed For The Sake Of Convenience, We Shall Take The Lead Case In Ita No.896/Rjt/2024 For Assessment Year 2013-14. Ita No. 896&897/Rjt/2024 Pari Anil Gandhi Rajkot

For Appellant: Shri D. M. Rindani, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav Ld. SR. DR

Section 115BSection 144BSection 147Section 154Section 234Section 234ASection 234BSection 250Section 271(1)(c)Section 68

help the Department to discharge the burden that lay upon it". 9. The assessee has further objected for re-opening of an assessment and borrowed satisfaction and reopened based on incorrect fact, in support of claim the assessee has also submitted various judgements before

Pari Anil Gandhi, Rajkot vs. Income Tax Officer, Ward - 2(1)(1) Rajkot, Rajkot

In the result, both the assessee’s appeals are allowed for statistical purpose

ITA 896/RJT/2024[2013-14]Status: DisposedITAT Rajkot05 Jan 2026AY 2013-14

For Appellant: Shri D. M. Rindani, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav Ld. SR. DR

Section 115BSection 144BSection 147Section 154Section 234Section 234ASection 234BSection 250Section 271(1)(c)Section 68

Maithan Ceramic Ltd., Kolkata vs. ACIT, Circle 7(1), Kolkata

ITA 1944/KOL/2025[2011-2012]Status: DisposedITAT Kolkata01 Jan 2026AY 2011-2012

For Appellant: Shri P.K.Himmatsinghka, ARFor Respondent: Shri Sandeep Lakra, Sr. DR

Section 142(1)Section 269S

IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, KOLKATA BEFORE SHRI GEORGE MATHAN, JUDICIAL MEMBER AND SHRI RAKESH MISHRA, ACCOUNTANT

Ajaykumar Natwarlal Sheth, Rajkot vs. The DCIT, Circle 1(2) Rajkot, Rajkot

ITA 108/RJT/2025[2010-11]Status: DisposedITAT Rajkot31 Dec 2025AY 2010-11

Section 143(1)Section 143(3)Section 147Section 148Section 250

आयकर अपीलीय अधिकरण, राजकोट न्यायपीठ, राजकोट । IN THE INCOME TAX APPELLATE TRIBUNAL, RAJKOT “SMC” BENCH, RAJKOT BEFORE DR. ARJUN LAL