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2018 (5) TMI 133 - ITAT DELHIReopening of assessment - bogus accommodation entries - Held that:- Merely because the statement was recorded on 12.12.2008 while making assessment for assessment year 2001-02, the same cannot be presumed that the said party was also issuing bogus accommodation entries for assessment year 2002-03. It has been held in various decisions that for the purpose of issuing notice u/s 148, the facts of one assessment year cannot be imported in another assessment order without due verification. The assessment for assessment year 2002-03 has been reopened on the basis of an undated assessment order for assessment year 2001-02. We find merit in the argument for the assessee that the re-assessment proceedings initiated by the Assessing Officer is not as per law. We, therefore, quash the re-assessment proceedings initiated by the Assessing Officer. Appeal filed by the assessee is allowed.
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