Dismissing the petition the Court held, that the search assessment was finalised under section 143(3) read with section 153A of the Act on March 28, 2016. Thereafter, survey action under section 133A of the Act was conducted by the Investigation Wing on January 14, 2017 in the case of B, proprietor of Swastik Corporation. During the course of the survey action, a statement of Shri Bijal Ashok Shah was recorded on oath wherein he admitted that he was engaged in the business of providing accommodation entries to the beneficiaries in lieu of commission. Shri Bijal Ashok Shah    also disclosed the modus operandi employed by him to provide the entries to the beneficiaries.  Shri Bijal Ashok Shah in his statement, had also named the petitioner as one of the recipients of the accommodation entries. All these facts were not before the Assessing Officer at the time of finalization of the search assessment. The notice of reassessment based on these facts was valid.  Refer,Amar Jewellers Ltd. v. ACIT  (2022) 444 ITR 97// 216 DTR 137 /  328 CTR  150/137 taxmann.com 249 (Guj.)(HC)  KKP Marketing (I) Ltd  v. Dy.CIT(2022) 444 ITR 97/ 216 DTR 137 /  328 CTR  150/ 137 taxmann.com 249( Guj)( HC)  (AY.2013-14)