Basant Dharmichand Jain v. Dy. CIT (2022)98 ITR 694 (Mum) (Trib)

S. 147 : Reassessment-After the expiry of four years-Bogus purchase-No disallowance made on account of bogus purchase-Reassessment proceedings quashed. [S.69C, 148]

Held, that the reasons for which the assessment of the assessee was reopened was only to make the disallowance on account of bogus purchases. Since, no disallowance was made in the reassessment proceedings on account of bogus purchases, the very basis of the reopening failed. (AY. 2007-08)