2017 (3) TMI 109

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....sessee was subjected to scrutiny assessment for AY 2001-02. In that year, it had issued additional share capital and received money from its investors. The scrutiny assessment was completed without significant additions. The reassessment notice was issued on 26.03.2008. The reassessment notice stated that information had been received in the Investigation Wing indicating that the assessee was the beneficiary of accommodation entries from certain established "entry operators". The relevant extract of the "Reasons to Believe" in support of Notice under Sections 147/148 is as follows: "Reasons for issuing notice u/s 148 of the Act in the case of M/s. Paramount Intercontinental (P) Ltd., for the AY 2001-02 - reg. In this case,....

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.... instant case, the assessee is found to be beneficiary of accommodation entry from such entry operators as per the following specific details of transaction:- XXXXXX XXXXXX XXXXXX The assessee has received unexplained sums from the entry operators as per the above details as per information available with the undersigned. As explained above, the identity, creditworthiness and genuineness of transactions with the persons found to be entry operators cannot be established. I, therefore, have reasons to believe that on account of failure on the part of the assessee to disclose truly and fully all material facts necessary for assessment for above assessment year, the income chargeable to tax to the extent of accommodation entry....