Reassessment Under Section 147 Quashed: AO's "Borrowed Satisfaction" Without Independent Inquiry Deemed Mere Suspicion

The ITAT upheld the CIT(A)'s decision quashing the reassessment proceedings under s.147 initiated after four years. The Tribunal found that the AO's reasons for reopening were based on borrowed satisfaction without independent application of mind, constituting mere "reasons to suspect" rather than "reasons to believe." The AO failed to conduct preliminary inquiries by examining the assessee's and M/s Frankdeal Traders Pvt. Ltd.'s tax returns and audited financial statements before issuing the notice. Additionally, the AO erroneously alleged the assessee received accommodation entries during FY 2010-11, when the assessment order itself acknowledged these entries were received by M/s Frankdeal Traders up to FY 2008-09. This contradiction rendered the reassessment proceedings illegal and bad in law. .....

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