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2023 (2) TMI 415 - ITAT KOLKATAReopening of assessment u/s 147 - reason to believe - HELD THAT:- Assessee has escaped from assessment and the AO on the specific information received from the Investigation Wings of the Department and information was not vague but was a specific information pertaining to the transaction made by the appellant by stating details of accommodation entry received by the assessee. Sanction has been granted in the background of facts and information which was part of the approval of the folder from the findings of the ld. CIT(A)’s order. We also gainful to state to the fact that the AO did not provide the assessee, the copy of reasons to believe recorded by him before furnishing notice u/s 148 of the Act to the assessee was not correct as the CIT(A) in his findings stated that as per order-sheet of AO Copy of the reasons recorded has been provided to the ld. AR. Therefore, ground taken by the assessee are not sustainable accordingly we dismiss the ground taken by the assessee. Addition u/s 68 - accommodation entry to deposit various cash/cheques from the parties - During the assessment proceedings, the ld. AO had given ample opportunity to the assessee but the assessee in his reply stated that now about 8 years have lapsed and he was not in touch with the beneficiaries, therefore, he could not provide the exact address of the parties. All the facts narrated above and the ld. CIT(A) categorically stated while passing his order by which he confirmed the addition made by the ld. AO. He after considering the facts of the case in our hand, we are of the considered view that the order passed by the ld. CIT(A) need not required to be interfered any more by this Tribunal and accordingly, we affirm the order passed by the ld. CIT(A) and set aside the grounds taken by the assessee.
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