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Borrowed Satisfaction and Mechanical U/s 151 Approval Invalidate 147 Reopening – ITAT Kolkata
Case Law Details
- TaxGuru Citation
- 2026 taxguru.in 2523
- Case Name
- Surana Bros Pvt. Ltd Vs ITO (ITAT Kolkata)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2009-2010
- Courts
- All ITAT, ITAT Kolkata
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Surana Bros Pvt. Ltd Vs ITO (ITAT Kolkata)
Reopening u/s 147 Quashed – Borrowed Satisfaction Mechanical Approval u/s 151 Held Invalid – No Independent Application of Mind – ITAT Kolkata
ITAT Kolkata quashed reassessment holding that AO reopened case solely on information received from Singapore without independent verification, amounting to borrowed satisfaction and non-application of mind. Tribunal observed that reasons recorded were factually incorrect and assessee had already disclosed capital gains properly. Further, approval u/s 151 was held invalid as PCIT granted ...
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