Reopening of Tax Assessment Justified: Brokerage Income Misattributed to Firm, Not Petitioner Company, Petition Dismissed.

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....Reopening of assessment u/s 147 justified due to tangible material available with Assessing Officer (AO) to form reasonable belief regarding escapement of income. Brokerage income shown in firm's profit and loss account belonged to petitioner company as confirmed by partner/director's statement recorded during survey. Firm claimed bad debts to offset brokerage income credited in its books to avoid tax liability for petitioner company which performed work. AO rightly relied on Supreme Court decision in ITO v. Atchaiah, as right person (firm) required to be taxed for income from work done for foreign company. Petitioner's contention of regularly showing brokerage income in firm's books is subject to AO's scrutiny during assessment proceedings.........