Tribunal held that the validity of reassessment proceedings has to be judged with the material available with the Assessing Officer and opinion are strictly based on documents and information in possession of the Assessing Officer. No reopening can be made in mechanical manner. Reopening cannot be based on borrowed satisfaction. The independent satisfaction of the Assessing Officer is the basic necessity.( AY.2007- 08, 2008 -09)
Nirmala Agarwal v. ACIT (2018) 64 ITR 658 (Jaipur) (Trib)
S.147: Reassessment —Merely on the basis of statement recorded by investigation wing and cross examination was not provided- Reopening assessment on borrowed satisfaction rather than his own satisfaction – Reassessment is held to be invalid [ S.148 ]