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2022 (5) TMI 442 - AT - Income TaxReopening of assessment u/s 147 - accommodation entry receipts - information received from the Investigation Wing that the assessee is allegedly one of the beneficiaries of having accommodation entries from a bogus concern operated by Shri Praveen Kumar Jain and group concerns - onus to substantiate your claim of the transaction - HELD THAT:- CIT(A) is correct in upholding the reopening. The Assessing Officer was in possession of tangible material which had live link with the prima facie belief that income has escaped assessment in as much as assessee was obtaining bogus accommodation entry. As regards merits of the case Assessing Officer has issued notice which had remained uncompliance with. The assessee’s plea of the assessee having no onus to prove the creditworthiness of the party is not sustainable on the touchstone of Hon'ble Bombay High Court Goa Bench decision in CIT Vs. Sadiq Sheikh [2020 (10) TMI 1028 - BOMBAY HIGH COURT] - Decided against assessee.
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