Assessment u/s 153A OR reopening of assessment u/s 147 - There ...

Court Rules Reassessment Requires AO's Independent Evaluation, Not Just Reliance on Investigation Reports u/s 153A.

June 10, 2022

Case Laws     Income Tax     AT

Assessment u/s 153A OR reopening of assessment u/s 147 - There is force in contention of counsel of assessee that as scrutiny assessment u/s. 153A in regard to assessee was conducted that all the more required to disclose the tangible material in regard to transaction requiring reassessment. There should have been an independent application of mind by the Ld. AO to the information out of the statement forming basis of allegations of accommodation entries. Merely reproducing the conclusions of investigation report in his own words is indeed borrowed satisfaction as contended by counsel for the assessee. Consequently, the Bench is inclined to decide these grounds of cross objection in favour of the assessee. - AT

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