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2018 (12) TMI 1449 - AT - Income TaxReopening of assessment - bogus purchases - Reopening within four years from the end of assessment year - Held that:- We uphold the validity of the reopening of assessment u/s 147 of the 1961 Act as originally return of income was processed u/s 143(1) and no assessment was framed u/s 143(3) of the 1961 Act. The notice u/s 148 was issued within four years from the end of assessment and first proviso to Section 147 of the 1961 Act is not applicable. Fresh and new tangible and material incriminating information was received by the AO as detailed above from DGIT(Inv.), Mumbai which in turn was based on incriminating information received from Maharashtra VAT authorities incriminating assessee to be beneficiary of alleged bogus purchases and accommodation entries which in our considered view keeping in view factual matrix of the case was sufficient to reopen the concluded assessment within parameters of Section 147 of the 1961 Act. Thus, based on our detailed reasoning as set out above, we affirm the appellate order passed by learned CIT(A) and dismiss the appeal of the assessee.
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