2019 (1) TMI 1020

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....y by the Assessing Officer by issuing notice under Section 148 of the Act. He had recorded reasons for issuing the notice which suggested that he had received information from the Sales Tax Department that the assessee had indulged in Havala entries and had not carried out actual trading activities with respect to certain sales. Pursuant to this notice, the Assessing Officer passed an order of assessment under Section 143(3) r/w Section 147 of the Act on 28th March, 2016 making certain additions to the assessee's declared income. 3. To reopen such assessment, the Assessing Officer issued the impugned notice. In order to do so, he had recorded following reasons: "The reason for issue of notice u/s 148 in your case for AY 201112 is as u....

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.... facts, I am of the opinion that the assessee's income to the extent of Rs. 1,28,71,907/(1,31,68,191 - 296284) has escaped assessment. Accordingly, the proceeding u/s 147 of the Income Tax Act, 1961 are duly attracted in order to frame proper assessment to bring to tax appropriate income on the issue of bogus entries of purchases and any other income which will be detected during the course of assessment proceedings. Therefore, this case is fit for issue of notice u/s 148 of the I.T. Act, 1961." 4. Upon being supplied the reasons, the assessee raised objections to the notice of reopening under letter dated 28th November, 2018. Such objections were rejected by the Assessing Officer by order dated 30th November, 2018. Hence, this petitio....