Case Law Details
Case Name : Principal Commissioner of Income Tax Vs Meenakshi Overseas Pvt Ltd (Delhi High Court)
Related Assessment Year :
Courts :
All High Courts Delhi High Court
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In the present case, as already noticed, the reasons to believe contain not the reasons but the conclusions of the AO one after the other. There is no independent application of mind by the AO to the tangible material which forms the basis of the reasons to believe that income has escaped assessment. The conclusions of the AO are at best a reproduction of the conclusion in the investigation report. Indeed it is a ‘borrowed satisfaction’. The reasons fail to demonstrate the link between the tangible material and the formation of the reason to believe
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