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2018 (5) TMI 1951 - AT - Income TaxValidity of the reassessment proceedings u/s 147 -Assessee has suppressed its profits by taking accommodation entries of bogus purchases - HELD THAT:- The intimation from DGIT (Inv), Mumbai was about the bogus investment/share applications. AO has not at all applied his mind while recording the reasons. The facts on record clearly establishes that the AO has not applied his mind so as to come to a conclusion that he has reason to believe that the income has escaped assessment for the year under consideration. The reasons recorded are vague and are not based on any tangible material as well as on the facts acceptable in the eyes of law. The reasons recorded also suggest that the AO has mechanically issued notice u/s 148 even not bothering regarding the nature of information received from the DGIT (Inv), New Delhi. Such vagueness in the reasons recorded make reopening bad in law and deserved to be quashed. Therefore, we quash the reopening of the assessment. Since we have quashed the notice issued for reopening assessment u/s 148 - Decided in favour of assessee.
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