Held that the reasons recorded for the formation of belief of escapement of income chargeable to Income-tax for the reopening of the completed assessment were found to be based on wrong and irrelevant facts, borrowed satisfaction and violation of principles of natural justice. All information was available when the original assessment was passed. Principal Commissioner gave approval without application of mind and without verifying facts from assessment record. Reassessment is invalid. (AY.2012-13)
Evershine Recreation P. Ltd. v. Dy. CIT (2023)107 ITR 65 (SN)(Chd) (Trib)
S. 147 : Reassessment-After the expiry of four years-Borrowed satisfaction-Contrary to facts-All information was available while passing the original assessment order-Approval without application of mind-Reassessment is bad in law. [S. 132, 133A, 148, 151, 153A, 153C]