Reopening solely relying upon information without forming independent opinion is liable to be quashed

Raajratna Stockholdings Pvt. Ltd. Vs ACIT (Gujarat High Court)

Gujarat High Court held that AO couldn’t assume jurisdiction to reopen assessment, without forming independent opinion, solely and mechanically relying upon the information received from the other sources. Accordingly, reopening u/s. 148 quashed.

Facts- By this petition under Article 226 of the Constitution of India, the petitioner has challenged a notice dated 30.03.2021 for reopening of assessment for A.Y.2013-14 issued under section 148 of the Income Tax Act,1961.

Conclusion-

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