TMI Blog2022 (8) TMI 208X X X X Extracts X X X X X X X X Extracts X X X X ..... tioner was to know which of the entities it dealt with were filers or non-filers. The impugned order states that a report was prepared against the Petitioner-company which concludes that the assessee had shown bogus purchases from bogus entities to suppress the profit of the company and reduce the tax liability during the years 2015-16 to 2020-21. However, no such report which forms the basis for the information on which the assessment was proposed to be reopened had been provided to the Petitioner. In fact, there are no specific allegations in the show cause notice to which the Petitioner could file a reply. Keeping in view the aforesaid, the impugned order dated 30th March, 2022 passed u/s 148A(d) and notice dated 31st March, 2022 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... assessment order dated 27th April, 2021 under Section 143(3) read with Section 144B of the Act was passed assessing the income of the Petitioner at Rs.6,41,76,500/-. He points out that one of the points for selecting the Petitioner s case for scrutiny was 'Business Purchases' and after analysing the documents submitted by the Petitioner, no additions were made by the Assessing Officer on account of business purchases. 3. Learned counsel for the Petitioner states that the impugned show cause notice dated 16th March, 2022 issued under Section 148A(b) of the Act did not provide any information and/or details regarding the income that has been alleged to have escaped assessment. He states that the Petitioner filed a response to the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ck of reconciliation between the ITR and GST Data of the Petitioner. He also states that no GST information showing substantial routing of funds was ever furnished to the Petitioner. 7. Having heard the counsel for parties, this Court is of the view that the impugned show cause notice as well as the impugned order under Section 148A(d) of the Act are based on distinct and separate grounds. 8. The show cause notice primarily states that it is seen that the Petitioner has made purchases from certain non-filers . However no details or any information of these entities was provided to the Petitioner. It is not understood as to how the Petitioner was to know which of the entities it dealt with were filers or non-filers! 9. Further, the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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