2023 (6) TMI 106

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....)"], for the assessment year 2011-12. 2. In this appeal, the assessee has raised the following grounds:- "1. The appellate order dated 27-05-2022 passed by CIT(A), National Faceless Appeal Centre, Delhi is quite arbitrary, illegal and contrary to the facts of the case of your appellant. 2. The Ld. CIT(A) has further erred in not allowing the claim of appellant in respect to the re- opening of assessments. 3. The case laws relied upon by him is not at all relevant to the facts and circumstances of the present case. 4. The Ld. CIT(A) has further grossly erred in rejecting the appellant's contention that there was no new information on record to warrant the initiation of proceedings u/s.148 of the Act....

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....under consideration, the assessee filed his return of income on 27/09/2011 declaring a total income of Rs.30,62,800/-. The return filed by the assessee was initially processed u/s 143(1) of the Act. Thereafter, on the basis of information received from DGIT (Inv.), Mumbai, proceedings u/s 147 of the Act were initiated, and notice u/s 148 of the Act was issued on 28/03/2018 in the case of the assessee. As per the said information, the assessee is a beneficiary of bogus purchases from a concern, viz. M/s Krishna Diam, of Gautam Jain Group, who are entry/accommodation bills provider. Accordingly, in absence of proof of the genuineness of purchases made by the assessee, the AO vide order dated 14/12/2018 passed u/s 143(3) r.w.s. 147 of the Act ....