TaxTMI 
TaxTMI 
2019 (12) TMI 1687
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....NOURABLE MS.JUSTICE HARSHA DEVANI 1. Mr. Manish Shah, learned advocate for the petitioner, invited the attention of the court to the reasons recorded for reopening the assessment, to submit that the Assessing Officer seeks to reopen the assessment on the ground that the petitioner company is a beneficiary of entries of Rs. 50,00,000/- from a transaction with Shri Pravin Agarwal and Shri Kamalkan....
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.... be reopened beyond a period of four years from the end of the relevant assessment year and that the Assessing Officer has proceeded on the basis that since no assessment has been made in the present case, the only requirement to initiate proceedings under section 147 of the Act is reason to believe. It was submitted that thus, the Assessing Officer has proceeded on a factually incorrect basis. ....
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....he petitioner had not responded to the notice under section 133(6) of the Act. It was pointed out that in the entire reasons recorded, there is not even a whisper regarding any failure on the part of the petitioner to disclose fully and truly all material facts and therefore, the assumption of jurisdiction by the Assessing Officer under section 147 of the Act, without there being any failure on th....