https://www.taxtmi.com/highlights?id=74667 Reopening of assessment u/s 147 - The High Court observed that, the expression “accommodation entry” and “bogus financial transaction” in the recorded reasons are not reason for formation of reasonable belief but are conclusions. - The HC further observed that it is also not clear whether the statement of “accommodation entry provider” is recorded U/s 132(4) or Section 133A, inasmuch as, a statement recorded U/s 133A has no evidentiary value. - The High Court quashed the proceedings / notice since the Assessment Order is passed on pure guess work without any relevant material which is contrary to mandates of Section 144 dealing with Best Judgment Assessment. en-us Tue, 06 Feb 2024 20:54:05 +0530 Tue, 06 Feb 2024 22:45:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=74667 Reopening of assessment u/s 147 - The High Court observed that, the expression “accommodation entry” and “bogus financial transaction” in the recorded reasons are not reason for formation of reasonable belief but are conclusions. - The HC further observed that it is also not clear whether the statement of “accommodation entry provider” is recorded U/s 132(4) or Section 133A, inasmuch as, a statement recorded U/s 133A has no evidentiary value. - The High Court quashed the proceedings / notice since the Assessment Order is passed on pure guess work without any relevant material which is contrary to mandates of Section 144 dealing with Best Judgment Assessment. Highlights Income Tax Tue, 06 Feb 2024 20:54:05 +0530 https://www.taxtmi.com/highlights?id=74667