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Notice U/s 147

Income Tax - Started By: - Saurav Dugar - Dated:- 3-6-2015 Last Replied Date:- 6-6-2015 - Please answer the Query with Case law if any X pvt ltd purchase from Mr. Y.Search & Seizure was Carried out on Mr. Y.A statement U/s 131(1) of Mr.Y was recorded wherein he had admitted that he has engaged in providing accommodation entries through his bougus Concern. X pvt ltd is also one of the beneficiaries assesed by Department.AO has Reason to believe that X pvt ltd has received bogus enteries from .....

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x that have escaped assessment has been provided under section 147 r w s 148 of Income Tax Act of 1961. If the assessing officer has the reason to believe that any income chargeable to tax has escaped assessment then the assessing officer may subject to the provisions of section 147 to 153 assess or reassess such income.Before issuing any notice U/S 148 the assessing officer must have reason to believe that any income chargeable to tax has escaped assessment. Reason to believe can not be a reaso .....

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o believe. If the assessee has disclosed basic and all the true facts during the course of assessment and the assessment is completed. Later on notice u/s 148 can not be issued merely because there is another inference possible from the same documents and the facts placed before the assessing officer during the course of assessment.But if the assessee has suppressed some relevant facts which leads to concealment of income and later those facts come before the assessing officer the /48 can be iss .....

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the end of the relevant assessment year, no such notice shall be issued unless the Chief Commissioner or Commissioner is satisfied, on the reasons recorded by the Assessing Officer aforesaid, that it is a fit case for the issue of such notice.In a case other than a case falling under sub-section (1) of section 151, no notice shall be issued under section 148 by an Assessing Officer, who is below the rank of Joint Commissioner, after the expiry of four years from the end of the relevant assessme .....

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