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2023 (8) TMI 822 - AT - Income TaxReopening of assessment u/s 147 - Reason to believe - basis of information received from the investigation wing - HELD THAT:- It is evident from the record that the Assessing Officer received the information from DGIT (Investigation) Wing, Mumbai about having vital information initially received from the Sales Tax Department of Maharashtra indicating that the assessee is a beneficiary of accommodation entries by way of bogus sales/purchase bills. On the basis of the aforesaid information, AO initiated proceedings u/s 147 of the Act and issued a notice u/s 148 correctly. If there is relevant material on the basis of which a reasonable person can form a requisite belief that income chargeable to tax has escaped assessment, then proceedings u/s 147 of the Act can be validly initiated. In the present case, on the basis of information received from the investigation wing, reassessment proceedings in the case of the assessee were initiated. It is also well settled that sufficiency or correctness of the material is not a thing to be considered at the stage of recording of reasons. As a result, we find no infirmity in the reassessment proceedings initiated by the AO u/s 147 of the Act and upheld by the CIT(A). Thus, the grounds raised by the assessee challenging the reopening of the assessment are dismissed.
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