Non-Application of Mind and Wrong AY Render Sec 147 Reopening Void – ITAT Kolkata

Labh Combines Pvt. Ltd. Vs DCIT (ITAT Kolkata) Reopening Quashed for Non-Application of Mind – Wrong AY Borrowed Satisfaction from Investigation Wing – Sec 147 Jurisdiction Invalid – ITAT Kolkata ITAT Kolkata quashed reassessment holding that AO reopened case mechanically based on investigation wing information relating to wrong financial year, demonstrating complete non-application of mind. Tribunal observed that reasons recorded merely reproduced third-party report without establishing live nexus with escapement of income for relevant AY, amounting to borrowed satisfaction. Relying on ...