Reopening of assessment u/s 147 - validity of reason to believe - ‘borrowed satisfaction’ of the DDIT...

Reopening of assessment u/s 147 - validity of reason to believe - ‘borrowed satisfaction’ of the DDIT (Inv.) - The repetition of certain portions of the investigation report of DDIT without any reasons independently recorded by the AO on the basis of ‘borrowed satisfaction’ of the DDIT (Inv.) cannot be the basis for reopening of assessment u/s. 147 of the Act. .....

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