2022 (3) TMI 665 - AT - Income Tax

Reopening of assessment u/s 147 - eligibility of reasons to believe - Bogus purchases - HELD THAT:- We have gone through the reasons recorded by the assessing officer and observe that the issue of notice u/s148 and assumption of jurisdiction for assessment by the AO was perfectly in accordance with law and his formation of belief for concealment of income was correctly based on material available with him at the time of issue of notice u/s148 of the Act. Consequently, the reassessment proceedings initiated by the AO is in accordance with law. Hence, this ground of appeal of the assessee is dismissed.

Estimation of income on bogus purchases - As the issue is squarely covered by the decision of the Coordinate Bench, in the case of Pankaj Choudhary [2021 (10) TMI 653 - ITAT SURAT] and there is no change in facts and law and the ld Counsel is unable to produce any material to controvert the aforesaid findings we find no reason to interfere in the said order of the Coordinate Bench, therefore, respectfully following the binding judgment of the Coordinate Bench, we sustain the addition @ 6% of impugned purchases.