Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2023 (8) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2023 (8) TMI 1113 - ITAT KOLKATAReopening of assessment - validity of reasons to believe - HELD THAT:-reasons state the incorrect assessment year on the top of the reasons recorded as A.Y. 2009-10 whereas in the bottom the same is stated as AY 2010-11. Besides we note that the AO has only referred to letter of the Investigation wing stating that the assessee has deposited cash in a number of dubious accounts however no such accounts were brought on record in the reasons recorded . In our opinion, there is no application of mind by the AO and this is the case of borrowed satisfaction as the AO has not applied his mind to the information received from Investigation Wing. Under this circumstance, we are not in a position to sustain the re-opening of assessment and therefore the same is bad in law.
|