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HC quashed and set aside the reopening order and notice. The court held that the AO erred in assuming jurisdiction under s.147 because credits in the account of a cooperative bank during the demonetisation window related to AY 2017-18, not AY 2018-19, and thus could not form the basis for reopening for the impugned year. The AO's reliance solely on transactions with an unnamed trader and the petitioner's alleged failure to produce books was inadequate to establish a prima facie escapement of income. The petitioner had already furnished ledger extracts and the tax audit report in response to the s.148A(b) notice. Consequently, the order under s.148A(d) and the s.148 notice were invalid and set aside.
HC quashed and set aside the reopening order and notice. The court held that the AO erred in assuming jurisdiction under s.147 because credits in the account of a cooperative bank during the demonetisation window related to AY 2017-18, not AY 2018-19, and thus could not form the basis for reopening for the impugned year. The AO's reliance solely on transactions with an unnamed trader and the petitioner's alleged failure to produce books was inadequate to establish a prima facie escapement of income. The petitioner had already furnished ledger extracts and the tax audit report in response to the s.148A(b) notice. Consequently, the order under s.148A(d) and the s.148 notice were invalid and set aside.
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