2014 (8) TMI 1088

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....f reassessment proceedings. Briefly stated, the facts of the case are that the assessee filed its return on 01.11.2004 which was processed u/s 143(1) of the Income-tax Act, 1961 (hereinafter also called 'the Act') on 23.02.05. Notice u/s 148 was issued on 20.03.2007 requiring the assessee to file its return. The assessee vide its letter dated 20.04.07 submitted that the original return filed may be treated as return filed pursuant to notice u/s 148. The AO mentioned in the assessment order to have received some information from the Investigation Wing, New Delhi about the involvement of the assessee in giving and taking accommodation entries. During the previous year relevant to the assessment year under consideration, the assessee received ....

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....ation gather by the DIT (Inv.)-I, New Delhi that the assessee was involved in giving and taking accommodation entries only and represented unsecured money of the assessee company is actually unexplained income of the assessee company. The assessee company has failed to disclose fully and truly all the material facts and source of these funds routed through bank accounts of the assessee company. I, therefore, have reasons to believe that the income has escaped assessment within the meaning of section 147 of the IT Act, 1961 for the asstt. Year referred above. Hence notice u/s 148 is issued Sd/- DCIT, Cir.11(1), N. Delhi." 5. A bare perusal of the above reasons indicates that these are general in nature not dealing with any specific giving....