Information from Investigation Wing from the documents seized at third party in Search action u/s 132 cannot be the sole basis for reopening, AO must make further enquiry and form his own “reason to believe” and not act on borrowed satisfaction.
The Tribunal held that the AO had not applied his mind and the reasons were based on vague information with no live link to escapement of income, the approving authority has also not bothered to verify the reasons before giving approval. Hence, approval is also bad in law
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