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2018 (4) TMI 1558 - AT - Income TaxReopening of assessment - bogus accommodation entries - Held that:- Investigation Wing had not analyzed the transaction of the accommodation entries prior to the Asstt. Year 2005-06 whereas the present case pertains to the Assessment Year 2004-05. Even the order of the learned AO does not reveal that he had undertaken any such exercise before the recording of the reasons. The reasons recorded do not specify the other party, who either received or provided the accommodation entries and they also do not establish the involvement of the assessee in the information unearthed by the Income-tax Department in respect of the huge money laundering mechanism. All these things, according to us, do not inspire any confidence in our mind to hold that the learned AO has reached any conscious decision that any income of the assessee has escaped assessment and the modus operandi thereof. While respectfully following the decision of the coordinate bench of the Tribunal in MRY Auto Components Ltd. (2017 (9) TMI 966 - ITAT DELHI) hold that the satisfaction of the learned AO is not based on any sound reasoning and on that ground, we hold that the reopening of assessment is bad. Allow the appeal of the assessee.
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