2026 (8) TMI 700

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.... 2. The petitioner filed original return of income of Assessment Year (for short 'AY') 2014-15 on 19.11.2014 disclosing income at Rs. 26,24,120/-. Scrutiny was undertaken and the assessment order under Section 143(3) of the Act was passed on 30.09.2016 determining total income at Rs. 26,24,120/-. Thereafter, the respondent issued the impugned notice under Section 148 of the Act dated 22.03.2019 reopening the assessment for the AY 2014- 15. Reasons for reopening were supplied vide letter dated 02.05.2019. The assessee raised various objections on merits and requested the respondent to drop the reassessment proceedings vide letter dated 04.12.2019. Thereafter, vide letter dated 11.12.2019 the respondent disposed of the objections. 3. Lear....

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....Learned advocate Mr. Soparkar has further submitted that there is no escapement of income. He has submitted that the assessee had paid M/s. Manibhadra Textile Company for the purchase of cotton in earlier year and thus, the assessee is having long business transactions with M/s. Manibhadra Textile Company and in such business relations, the payment had been made in earlier year. Thus, in absence of any payment at all to M/s. Manibhadra Textile Company during the year under consideration, it is urged that the present writ petition may be allowed. 5. Opposing the present writ petition and the submissions advanced by the learned advocate appearing for the petitioner, learned Senior Standing Counsel Mr.Dev Patel appearing for the respondent ....

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....subjected to scrutiny assessment and finally an order under Section 143(3) of the Act was passed on 30.09.2016, assessing the total income at Rs. 26,24,120/-. However, thereafter, the impugned notice under Section 148 of the Act was issued on 22.03.2019, seeking reopening of the assessment. The reopening is premised on the investigation report of ADIT (Inv.), raising suspicion about the cash withdrawal done by the assessee of M/s. Manibhadra Textile Company i.e. proprietorship firm of Shri Bhavesh Sureshchandra Shah. It is alleged that on verification of the bank account statements of M/s. Manibhadra Textile Company, it has been noticed that it has received credits from three concerns including the petitioner, and thereafter, Shri Bhavesh S....