Notice U/s 147

[Asked by Guest]

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 Mr.Y and has escaped assessement u/s 147.

My query wether the case was fit for re-opening u/s 147 base on search carried on third party from that A.O has Reason to believe that X pvt ltd has Escaped income is A.O tenable to open a case U/s 147. if not please provide remedy for that with supporting Case law..Thank U..

AI Summary

Reason to believe standard governs reassessment-new material or nondisclosure is required before reopening an assessment.
Reopening under section 147/148 demands a recorded reason to believe based on new material that directly links to escapement of income; mere suspicion or a change of opinion is insufficient. Valid reopenings rest on disclosure failures or freshly discovered material, subject to statutory authorisation and time-limit controls. On receiving a section 148 notice the assessee should file the return, obtain the reasons recorded, raise specific objections seeking a speaking order, and may pursue writ remedies if the reopening lacks statutory basis.