High Court Upholds Reopening of Assessment u/s 147 Due to Non-Disclosure of Material Facts in Initial Scrutiny.

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....Validity of reopening of assessment u/s 147 - accommodation entries - In the instant case, the notice under Section 148 of the Act has been issued by the assessing officer after receipt of information and conducting an investigation and after forming a reason to believe that the petitioner did not truly and fully disclose all the material facts at the time of limited scrutiny assessment, and it has been discovered subsequently during investigation that all the companies through which the entire share business has been dealt with by the petitioner, are bogus shell companies - We are satisfied that there is prima facie material available on record before the AO - HC....