Held, dismissing the writ petition, that a notice under section 148 of the Income-tax Act, 1961 was issued calling upon the assessee to deliver a return in the prescribed form for the assessment year 2012-2013. The authority received information from the Investigation Wing, Kolkata, during the year under consideration that the assessee made transaction in penny stock in the scrips of Twenty First Century (I) Ltd for an amount of Rs. 6,49,000. On the basis of material before it, if the Assessing Officer was satisfied to harbour reasons to believe that there was escapement of income and if on such basis, he had exercised his powers under sections 147 and 148 of the Income-tax Act, 1961, no fault could be found. The notice of reassessment was valid. (AY.2012-13)
Akshat Pramodkumar Chaudhary v. Dy. CIT [2023] 153 taxmann.com 25 /(2025) 482 ITR 860 (Guj)(HC)
S. 147: Reassessment-Sufficiency of reasons cannot be considered at the stage of notice-Notice based on information from the Income-tax Investigation Wing is valid.[S. 148, Art. 226]
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