Dismissing the petition the Court held that, there was no scrutiny assessment, therefore the question of change of opinion will not arise, information supplied by the Investigation Wing to the AO formed a prima facie basis to form the opinion that income chargeable to tax has escaped assessment. (AY. 2011-12)
Avirat Star Homes Venture (P) Ltd. v. ITO (2019) 411 ITR 321 / 173 DTR 207 / 261 Taxman 184/(2020) 313 CTR 728(Bom.)(HC)
S. 147 : Reassessment-Report of investigation Wing- Accommodation entries–Assessment u/s.143(1)-Notice for reassessment is valid. [S. 143(1), 148]