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Documents citing The Dcit, Circle-1(3), Ahmedabad vs Edelweiss Broking Ltd., Ahmedabad on 3 December, 2020

Sangeeta Devi Anchalia,Kolkata vs Ito, Ward-32(1), Kolkata on 2 January, 2025

05. We note that the above reasons indicate that a report received by the ld. AO from PCIT Investigation Kolkata vide letter dated 13.01.2015, and thereafter the ld. AO concluded that the income to that extent has escaped assessment. In our opinion this is the case of non- enquiry by the ld. AO and only re-opening on the basis of information received and arriving at the conclusion without any independent application of mind and in fact a case of borrowed satisfaction. The case of the assessee find force from the decision of Hon'ble Delhi High Court in case of CIT Vs. SFILl Stock Broking Ltd.(2010) 325 ITR 285 and M/S Shreyans Jain, Huf Vs. ITO 357 ITR 330. Accordingly, taking into account the ratio laid down in the above decisions and the facts of the instant case at hand, we are of the view that the reopening of assessment u/s 147 of the Act is invalid and void ab initio. Accordingly, the proceedings u/s 147 of the Act and also the consequent order passed are quashed.
Income Tax Appellate Tribunal - Kolkata Cites 9 - Cited by 0 - Full Document
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