S. 147: Reassessment-Information from Insight Portal-Allegation of accommodation entries-No independent inquiry conducted or evidence recorded to establish nexus with assessment records-Reasons recorded not sufficient to form bona fide belief of escapement of income-Reopening based on borrowed satisfaction and for fishing inquiry-Notice and consequential orders were quashed-Change of name and permanent account number not resulting in change of territorial jurisdiction-Assessing Officer before whom return had been filed earlier has jurisdiction to issue notice [S. 120, 124, 148,Art. 226]
Held that no independent inquiry was conducted or evidence recorded to establish nexus with assessment records. Reasons recorded were not sufficient to form a bona fide belief of escapement of income. Reopening based on borrowed satisfaction and for fishing inquiry; hence notice and consequential orders were quashed. Court also held that a change of name and permanent account number does not result in a change of territorial jurisdiction. Assessing Officer before whom return had been filed earlier has jurisdiction to issue notice. (AY. 2017-18)
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