TaxTMI 
TaxTMI 
2026 (1) TMI 1316
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....61 (hereinafter referred to as 'the Act') for the Assessment Year (AY) 2018-2019. 2. The assessee, in this appeal, has taken the following grounds of appeal: "1. The reopening of the assessment is bad in law in as much there is no live nexus between the information received and formation of belief. 2. The learned AO has erred in reopening of the assessment in as much as it is nothing but change of opinion since the AO has already examined all the transactions during assessment proceedings. 3. The learned CIT(A) has erred in confirming the addition of Rs. 4,34,09,924 as unexplained cash credit under Section 68 of the Act considering that the assessee has managed accommodation entries from Chaniyara Agro Industri....
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....19,60,276/- from the said Chaniyara Agro Industries Pvt.Ltd. Accordingly, a show-cause notice u/s. 148A (b) of the Act was issued by the Assessing Officer (AO) to the assessee. The assessee filed its reply denying any receipt of accommodation entry. However, the AO noticed that the assessee, during the year, had received a total amount of Rs. 4,34,09,924/- from Chaniyara Agro Industries Pvt.Ltd. Since in his statement Shri Sandip Maganbhai Chaniyara had admitted to have provided accommodation entries to various beneficiaries, therefore, the AO passed an order u/s. 148A(d) of the Act, rejecting the contention of the assessee and thereby reopened the assessment u/s. 148 of the Act. Thereafter, the AO framed the assessment and treated the sale....
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....ue of the bills, whereas, the fact on the file was that the assessee had made sales of Rs. 4,34,09,924/- to Chaniyara Agro Industries Pvt.Ltd. He has submitted that the AO, without verifying the said information with the accounts of the assessee, has reopened the assessment. He, therefore, has submitted that the re-opening of the assessment has been made by the AO on the basis of borrowed satisfaction of the Investigation Wing (IW). He has submitted that the information received from the IW was factually wrong and, therefore, the reopening of the assessment without correlating to the said information with the accounts of the assessee was bad in law. The Ld.DR, however, has relied upon the finding of the Ld. CIT(A) on these issues. 4. We ....
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....credit on account of accommodation entry received from Chaniyara Agro Industries Pvt.Ltd. 6. We have heard the rival contentions on this issue. Admittedly, the assessee is engaged in the business of trading of edible oil. Though the AO had information that Shri Sandip Maganbhai Chaniyara was engaged in providing accommodation entries through his concern - Chaniyara Agro Industries Pvt.Ltd. and that the assessee was one of the beneficiaries, however, the Ld. Counsel for the assessee, referring to the statement of Shri Sandip Maganbhai Chaniyara, as reproduced in the assessment order, has submitted that the name of the assessee was not mentioned by Shri Chaniyara in his statement recorded u/s. 131 of the Act. The Ld. DR, however, has invit....