Reassessment approval and limitation were upheld, while disputed purchase additions were remanded for fresh factual verification.

Reassessment proceedings were upheld where the notice recorded prior approval of the specified authority and the record showed initiation within the amended limitation period, so the jurisdictional objection failed. On the disputed purchases, adverse material from investigation and GST authorities indicated accommodation entries and bogus invoices, but the assessee relied on books, stock records, invoices, bank entries and sales evidence. As transportation proof, purchase-to-sale correlation and rebuttal of third-party material remained deficient, the Tribunal held that actual receipt of goods and supplier genuineness required further verification and restored the matter for fresh adjudication.

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Issues: (i) Whether the reassessment proceedings were validly initiated within limitation and with the requisite approval under the post-amendment reassessment regime. (ii) Whether the addition on account of alleged bogus purchases should be sustained in full or whether the matter required fresh adjudication.

Issue (i): Whether the reassessment proceedings were validly initiated within limitation and with the requisite approval under the post-amendment reassessment regime.

Analysis: The notice issued at the pre-assessment stage expressly recorded prior approval of the specified authority. The record showed that the proceedings were commenced within the period prescribed for the relevant assessment year under the amended reassessment provisions. The objection regarding absence of approval was not supported by the record, and the limitation challenge was based on an incorrect factual premise.

Conclusion: The reassessment challenge was rejected.

Issue (ii): Whether the addition on account of alleged bogus purchases should be sustained in full or whether the matter required fresh adjudication.

Analysis: The assessment and appellate records contained adverse material from the investigation and GST authorities suggesting accommodation entries and bogus invoices, while the assessee also relied on books of account, stock records, invoices, bank entries and sales evidence. The Tribunal noted deficiencies in transportation evidence, purchase-to-sale correlation, and rebuttal of the adverse third-party material. At the same time, it considered that the dispute required deeper factual verification as to actual receipt of goods and the genuineness of the suppliers.

Conclusion: The matter was restored to the Assessing Officer for fresh adjudication.

Final Conclusion: The jurisdictional objection failed, but the dispute on the disputed purchases was not finally decided on merits and was sent back for reconsideration after further verification.

Ratio Decidendi: Where adverse third-party material casts serious doubt on purchases, the assessee must establish actual receipt of goods through cogent evidence, and where the facts remain insufficiently verified, remand for fresh adjudication is appropriate.

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