mind. It was assailed on the ground of being " a
borrowed satisfaction".
4. Aggrieved by this action, the assessee went in appeal before ... reopening on the ground that it was based on "borrowed satisfaction".
3 ITA No. 1202/Del/09
Asstt. year
initiating proceeding u/s 147 on the basis of borrowed
satisfaction.
5) Without prejudice to ground nos. I to 4, on facts ... settled
law
IN CONNECTION WITH "REASONS RECORDED BY AO" -
BORROWED SATISFACTION
Refer page.4 of PB-1 -- reasons recorded
initiating proceeding u/s 147 on the basis of borrowed
satisfaction.
5) Without prejudice to ground nos. I to 4, on facts ... settled
law
IN CONNECTION WITH "REASONS RECORDED BY AO" -
BORROWED SATISFACTION
Refer page.4 of PB-1 -- reasons recorded
initiating proceeding u/s 147 on the basis of borrowed
satisfaction.
5) Without prejudice to ground nos. I to 4, on facts ... settled
law
IN CONNECTION WITH "REASONS RECORDED BY AO" -
BORROWED SATISFACTION
Refer page.4 of PB-1 -- reasons recorded
initiating proceeding u/s 147 on the basis of borrowed
satisfaction.
5) Without prejudice to ground nos. I to 4, on facts ... settled
law
IN CONNECTION WITH "REASONS RECORDED BY AO" -
BORROWED SATISFACTION
Refer page.4 of PB-1 -- reasons recorded
initiating proceeding u/s 147 on the basis of borrowed
satisfaction.
5) Without prejudice to ground nos. I to 4, on facts ... settled
law
IN CONNECTION WITH "REASONS RECORDED BY AO" -
BORROWED SATISFACTION
Refer page.4 of PB-1 -- reasons recorded
eyes of the law being based on 'borrowed satisfaction' without
application of mind by the Assessing Officer (AO) recording alleged 'satisfaction ... said that the Assessing Officer was
reopening the assessments on borrowed satisfaction in these group of cases. It
was submitted that reasonable grounds existed
reason to believe in this case are based on 'borrowed
satisfaction' ignoring the fact that the Investigation Wing is also ... Appellant was borrowed from the
Investigation Wing. Any notice issued under Section 148 of the Act
on the basis of borrowed satisfaction
open
assessment proceeding under section 147 of the Act based on borrowed
satisfaction and merely on the basis some information available with ... from the Directorate of Income Tax (Investigation). It was a "Borrowed
satisfaction". The relevant extract of the information received from the DDIT
that
there is no tangible material and it is merely a borrowed satisfaction and hence reopening
ITA No.2144 ... reason to
believe", relying instead on "Borrowed Satisfaction" of the ADIT(lnv), Kolkata, whence
the information flowed (refer pages
