Navnirman Infracon Private ... vs Ito, Ward 10(2), , Kolkata on 28 October, 2025
The case of the assessee find support from the decisions of
CIT Vs. Insecticides (India) Ltd. (2013) 38 taxmann.com 403 (Delhi),
Girishbhai Dahyabhai Patel vs. DCIT (2025) 474 ITR 299, CIT Vs. Atul Jain
P a g e 10 | 12
ITA No.689/Kol/2025
Assessment Year : 2011-12
(2008) 299 ITR 383 (Delhi) and Hindustan Lever Ltd. Vs. R.B. Wadekar
(2004) 137 taxman 479 (Bom). We also note that there is no independent
application of mind by the ld. AO to the information received and therefore,
this is at best a case of borrowed satisfaction by the ld. Assessing Officer.
Considering these facts and circumstances and in the light of aforesaid
decisions, the reopening is bad in law and so is the consequent assessment
framed. Therefore the re-opening as well as the assessment framed are
quashed.