TMI BlogReassessing Accommodation Entries: Insights from a High Court JudgmentX X X X Extracts X X X X X X X X Extracts X X X X ..... orders of the Income Tax Officer under Section 148A(d) of the Income Tax Act 1961. This case presents a compelling analysis of the legal intricacies surrounding reassessment proceedings, accommodation entries, and the role of judicial review in tax evasion cases. Background and Facts The case originated from a writ petition filed against the order of the Income Tax Officer (ITO) pertaini ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s were initiated on erroneous grounds, as they had disclosed the income from the sale of shares as Short Term Capital Gains (STCG). Allegations of Accommodation Entries : The core of the case revolved around the allegation that the petitioners were beneficiaries of bogus accommodation transactions. Judicial Review and Limitation : The petitioners argued that the notice issued w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ding that disputed questions of fact could not be adjudicated in a writ court. It was determined that the matter should be decided by the Assessing Officer on its merits, without the High Court examining the merits of the controversy. Subsequently, Apex Court also refused to interfere into the matter [ 2023 (6) TMI 1045 - SC ORDER ]. Implications This decision underscores the stringent ap ..... X X X X Extracts X X X X X X X X Extracts X X X X
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