Timely Reassessment Notice Issued; AO Follows Procedures for Bogus Purchase Disallowance Limited to 6.

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....Reassessment notice u/s 148 was validly issued within the six-year time limit. The Assessing Officer (AO) recorded reasons for reopening on 19.03.2018, prior to obtaining sanction u/s 151 on 23.03.2018, and issued the notice on 27.03.2018, before the deadline of 31.03.2018. The AO followed the procedure mandated by the Income-tax Act, 1961, and the Supreme Court's decision in GKN Driveshafts (India) Ltd. case. The AO had valid reasons to believe based on information from the investigation wing about bogus entries provided by entry operators. Regarding estimation of income from bogus purchases, following the Pankaj K. Chaudhary case, the disallowance was restricted to 6% of the disputed bogus purchases, as the books of account were not rejected.....