Borrowed Satisfaction & Zero Independent Enquiry: ITAT Delhi Sets Aside Reassessment

Marigold Merchandise Private Limited Vs ACIT (ITAT Delhi) Borrowed Satisfaction & Zero Independent Enquiry—ITAT Delhi Sets Aside Reassessment & Deletes 1% Commission Addition-No Tangible Material, No Application of Mind: ITAT Strikes Down 148 Notice Based Solely on Investigation Wing Inputs Assessee had originally been assessed u/s 153B(1)(b) r.w.s. 143(3) on 29.03.2014. AO later reopened the case u/s 147 by issuing notice u/s 148 on 31.03.2019—well beyond four years. Tribunal noted that in such cases the proviso to Sec.147 mandates AO to clearly demonstrate Assessee’s failure to...