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| The Tax Publishers2020 TaxPub(DT) 1975 (Del-Trib) INCOME TAX ACT, 1961
Section 147
Reason to believe had been formed after careful consideration and sound analysis of highly incriminating and self-explanatory material in possession of AO i.e. information emanated from Investigation Wing based on search carried out in case of entry provider. Further, process of administrative approval and recording of reasons could not be completed without due application of mind. Accordingly, reassessment proceedings were duly valid.
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Reassessment - Validity - Reason to believe - Due application of mind on AO'S part to information received from Investigation Wing
AO received information from Investigation Wing based on search carried out in case of entry provider, one 's' that assessee was also one of the beneficiaries of accommodation entries aggregating to Rs. 30 lacs. Accordingly, AO reopened assessment. Assessee challenged validity thereof on the ground of no independent application of mind on AO'S part. Held: Reason to believe had been formed after careful consideration and sound analysis of highly incriminating and self-explanatory material in possession of AO. Further, process of administrative approval and recording of reasons could not be completed without due application of mind. Accordingly, reassessment proceedings were duly valid.
REFERRED :
FAVOUR : against the assessee
A.Y. :
INCOME TAX ACT, 1961
Section 68
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