High Court the reassessment notice on the ground that the reasons recorded do not suggest at all whether pursuant to receipt of information, the assessing officer had independently applied its mind to the information received or conducted its own inquiry into the matter for the purpose of coming to a conclusion that indeed income assessable to tax had escaped assessment or that the transaction in question with the alleged shell entity was only a paper transaction. Accordingly the reassessment notice and order disposing the objection was quashed. SLP of Revenue is dismissed on account of delay of 354 days had not been satisfactorily explained and also on merits.(AY.2016-17)
ACIT v. B. U. Bhandari Autolines Pvt. Ltd. (2025)472 ITR 1 /171 taxmann.com 130 (SC) Editorial : B. U. Bhandari Autolines (P.) Ltd. v. Asstt. CIT (2023) 292 Taxman 195/ 456 ITR 56 (Bom)(HC)
S. 147 : Reassessment- With in four years- Accommodation entries- Shell company- Deposit of demonetized cash- Sales Borrowed satisfaction- Not independently applied the mind- Reassessment notice and order disposing the objection was quashed-Delay of 354 days- SLP of Revenue is dismissed on account of delay as well as on merits. [S. 69A, 143(1), 148, Art.136]