Borrowed Satisfaction Invalidates Reopening Under Section 147

Sushil Mitruka Vs DCIT (ITAT Kolkata) Borrowed Satisfaction Backfires — Reopening Quashed; Cash Deposits Explained, Revenue Appeal Crumbles Kolkata ITAT delivered a sweeping relief to Sushil Mitruka for AYs 2014-15 to 2017-18, holding that the very foundation of reassessment was illegal. The Tribunal found that reopening u/s 147 was based purely on borrowed satisfaction from DDIT (Investigation), with the AO mechanically reproducing the investigation report without any independent application of mind or formation of his own “reason to believe”. Such reopening, the Tribunal held, is imper...