2018 (2) TMI 1944

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....law that arises for consideration is:- (1) Whether the Income Tax Appellate Tribunal (ITAT) fell into error in holding that re-assessment notice and further proceedings under Section 147 of the Income Tax Act, 1961 were invalid? The assessment in respondent assessee's case was completed under Section 143(1) of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') for the A.Y. 2006-07,....

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....assessment was invalid. This Court has considered the submissions. The "Reasons to believe" in this case recorded by the ITAT are as follows:- "Kindly find enclosed herewith letter dated 13/03/2013 of ACIT, Central Range-IV, along with its enclosures on the subject mentioned above. 1. The assessment of search cases of Sh. Rakesh Gupta, Sh. Vishesh Gupta, Sh. Navneet Jain & Sh.Vaibhav Jain ....

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.... list is enclosed as annexure-C, duly signed by Sh.Vaibhav Jain. Thus, the firms mention in the list 'B' have provided accommodation entries to the firms mentioned in list 'C'. 4. The soft copy of the information in respect to annexure A, B and C is also enclosed. 5. The information of accommodation entry includes AY 2006-07 also, which is a time barring year for taking action u/s 14....