Bhagwati Polyfill (P.) Ltd. v. ACIT (2024) 296 Taxman 434 (Guj.)(HC)

S. 147 : Reassessment-After the expiry of four years-Unsecured loan-Accommodation entries-No tangible material-Suspicion-Reassessment notice and order disposing the objections are quashed.[S. 68, 148, Art. 226]

Allowing the petition the Court held that  no material came forth in terms of any statement or details to pin-point a live link or a nexus of assessee with transaction in question in reasons recorded.  There was no tangible material so as to come to a conclusion or reason to believe that income chargeable to tax had escaped assessment. Since reassessment was merely based on suspicion notice and order disposing the objection is quashed. (AY. 2011-12)