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The High Court dismissed the assessee's petition challenging the reopening of assessment u/s 147. The Assessing Officer had reasons to believe that the assessee's income had escaped assessment due to the lack of credibility of certain suppliers from whom purchases were made for export of garments. One of the suppliers, Balaji Enterprises, was found non-existent at its principal place of business during the investigation. The assessee failed to produce material establishing the credibility of Balaji Enterprises or Dev Sales Corporation. The court held that at the stage of issuing notice u/s 148, the Assessing Officer is only required to have reasons to assume income has escaped assessment, and the reopening process u/s 148A was duly followed. The court found no grounds to interfere with the impugned order and notice issued u/s 148.
The High Court dismissed the assessee's petition challenging the reopening of assessment u/s 147. The Assessing Officer had reasons to believe that the assessee's income had escaped assessment due to the lack of credibility of certain suppliers from whom purchases were made for export of garments. One of the suppliers, Balaji Enterprises, was found non-existent at its principal place of business during the investigation. The assessee failed to produce material establishing the credibility of Balaji Enterprises or Dev Sales Corporation. The court held that at the stage of issuing notice u/s 148, the Assessing Officer is only required to have reasons to assume income has escaped assessment, and the reopening process u/s 148A was duly followed. The court found no grounds to interfere with the impugned order and notice issued u/s 148.
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