Mere mention of receipt of information from DCIT not makes an Assessment/Notice as based on borrowed belief

Raju Bhupendra Desai Vs ITO (Gujarat High Court) There is also no merit in the submission of Mr. Patel that the respondent was carrying out fishing and roving inquiry completely on incorrect facts and based on the borrowed belief of DCIT Central Circle-1(3), Ahmedabad. It may be noted that merely because in the reasons recorded to reopen the case under section 153C, the respondent has recorded in the first opening paragraph that he had received the information from DCIT Cen, Cir-1(3), Ahmedabad, it could not be said that the respondent had borrowed the belief from the other officer or that he ...