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The reopening of assessment u/s 147 was based on information received from the tax department's investigation wing regarding two entities from whom the petitioner had availed supplies. The principal allegation was that the petitioner had availed accommodation entries from these two non-existent suppliers, suggesting that the petitioner's income for the relevant assessment year escaped assessment. Although the petitioner produced documents supporting genuine purchases, no material was provided to establish the creditworthiness or substance of the two named entities. The High Court held that the Assessing Officer had sufficient grounds to suggest that the assessee's income had escaped assessment, and it was not necessary for the court to adjudicate the allegations at this stage. The petition was dismissed.
The reopening of assessment u/s 147 was based on information received from the tax department's investigation wing regarding two entities from whom the petitioner had availed supplies. The principal allegation was that the petitioner had availed accommodation entries from these two non-existent suppliers, suggesting that the petitioner's income for the relevant assessment year escaped assessment. Although the petitioner produced documents supporting genuine purchases, no material was provided to establish the creditworthiness or substance of the two named entities. The High Court held that the Assessing Officer had sufficient grounds to suggest that the assessee's income had escaped assessment, and it was not necessary for the court to adjudicate the allegations at this stage. The petition was dismissed.
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