Reopening of assessment based on borrowed satisfaction not sustainable: Gujarat HC

Ashishbhai Jashwantbhai Desai HUF  Vs ITO (Gujarat High Court)

Gujarat High Court held that reopening of assessment based on borrowed satisfaction without there being any link between information and data available on record is unsustainable in law. Accordingly, notices are liable to be quashed and set aside.

Facts- By this petition Article 226 of the Constitution of India, the petitioners have challenged the notice dated 30^th March, 2021 issued under Section 148 of the Income Tax Act, 1961 for Assessment Year 2017-18.

Notably, the petitio

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