Reopening under section 147 after a search was upheld, as the tribunal found no infirmity in the assumption of jurisdiction and rejected the challenge to validity of reassessment. On the merits, commission income from an accommodation entry operation was to be estimated at 0.15%, not the higher rate proposed by the Assessing Officer, but the quantification basis was vitiated because the tally data and forensic analysis report had not been confronted to the assessee. That breach of natural justice required fresh computation. The matter was remanded to the Assessing Officer to supply the material, consider the assessee's submissions, recompute turnover, and then apply the 0.15% rate; the Revenue's challenge to that rate was dismissed.
Reopening under section 147 after a search was upheld, as the tribunal found no infirmity in the assumption of jurisdiction and rejected the challenge to validity of reassessment. On the merits, commission income from an accommodation entry operation was to be estimated at 0.15%, not the higher rate proposed by the Assessing Officer, but the quantification basis was vitiated because the tally data and forensic analysis report had not been confronted to the assessee. That breach of natural justice required fresh computation. The matter was remanded to the Assessing Officer to supply the material, consider the assessee's submissions, recompute turnover, and then apply the 0.15% rate; the Revenue's challenge to that rate was dismissed.
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