AO Must Independently Apply Mind; Non-Application Vitiates Reassessment

PCIT Vs Agfa India Pvt. Ltd. (Bombay High Court) Bombay High Court has upheld an Income Tax Appellate Tribunal (ITAT) order, dismissing an appeal by the Principal Commissioner of Income Tax (PCIT) against Agfa India Pvt. Ltd. The High Court’s decision centered on the critical principle that an Assessing Officer (AO) must possess an independent “reason to believe” that income has escaped assessment, rather than acting under the dictation or borrowed satisfaction of superior authorities or other wings of the Income Tax Department. The case involved Agfa India Pvt. Ltd., a compa...