https://www.taxtmi.com/caselaws?id=449129 The Jharkhand HC quashed the reopening of assessment under section 147 for alleged accommodation entries and bogus financial transactions. The court found no nexus between available material and the assessing officer's belief formation. The statement of an alleged accommodation entry provider under section 133A lacked evidentiary value, contained no direct reference to the petitioner, and had no specified date linking it to the relevant assessment year. The court held that proceedings initiated for verification and roving enquiry are impermissible under sections 147/148. The assessment was based on conjecture without tangible material, violating best judgment assessment principles. The belief formation was found to be vague, far-fetched, and lacking bona fides. The petition was decided in favor of the assessee. en-us Thu, 25 Jan 2024 00:00:00 +0530 Fri, 03 May 2024 10:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=449129 The Jharkhand HC quashed the reopening of assessment under section 147 for alleged accommodation entries and bogus financial transactions. The court found no nexus between available material and the assessing officer's belief formation. The statement of an alleged accommodation entry provider under section 133A lacked evidentiary value, contained no direct reference to the petitioner, and had no specified date linking it to the relevant assessment year. The court held that proceedings initiated for verification and roving enquiry are impermissible under sections 147/148. The assessment was based on conjecture without tangible material, violating best judgment assessment principles. The belief formation was found to be vague, far-fetched, and lacking bona fides. The petition was decided in favor of the assessee. Case-Laws Income Tax Thu, 25 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449129