The High Court held that the reopening of assessment u/s 147 did...

The High Court held that the reopening of assessment u/s 147 did not violate the provisions of Section 148A. The respondents provided the petitioners an opportunity of being heard as specified in the order. The court found that the impugned orders mentioned the non-genuine accommodation entries made by Shri Ashok Kumar Gupta through various firms controlled by him, including M/s Kalki Trading Company and M/s Swastik Traders. The petitioners admitted transactions with these firms, involving the purchase and sale of commodities on the same day, indicating paper transactions. The court opined that the impugned orders u/s 148A(d) did not violate Section 148A, and the transactions being bogus, the petitioners' contentions regarding sale and not purchase lost their effect. The impugned orders did not fall within the exceptions settled by the Supreme Court in Godrej Sara Lee case.