Income has escaped assessment is a pre-condition for re-opening the assessment and not a borrowed satisfaction from outside source
ITAT Kolkata holds that “…….We note that the AO has recorded a very cryptic reasons and it is a case of borrowed satisfaction and not the AO’s own satisfaction without any application of mind to the information received by the AO.
In our opinion, it is the satisfaction of the ld. AO that income has escaped assessment is a pre-condition for re-opening the assessment and not a borrowed satisfaction from outside source……”
The copy of the order is as under:
