Reopening of assessment quashed due to lack of independent application of mind by AO.

The HC quashed the reopening of assessment u/s 147, holding that the AO did not apply independent mind and relied solely on borrowed satisfaction from information on the insight portal without verifying material facts. The petitioner had disclosed share transactions through contract notes, ledger, and bank statements. The AO failed to form reasonable belief of income escapement as the disclosed profits were already offered to tax and accepted in regular assessment. Mere information from the insight portal, without examining assessee's records, cannot be a valid reason to believe income has escaped assessment. .....

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