Borrowed Satisfaction and Mechanical U/s 151 Approval Invalidate 147 Reopening – ITAT Kolkata

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 inval

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