Bharatkumar Kalubhai Ghadiya v. CIT (2021) 438 ITR 443 / 283 Taxman 254 / (2022) 324 CTR 388 209 DTR 291 (Guj.)(HC)

S. 147 : Reassessment-After the expiry of four years-Tangible material-Accommodation entries-Bogus companies-Information from investigation wing-Reassessment notice is valid. [S. 143(3), 148, Art. 226]

Dismissing the petition the Court held that the Assessing Officer had reason to believe that the assessee was a beneficiary of accommodation entry and the basis for formation of such belief were several inquiries and the investigation by the Investigation Wing and report thereof. The reasons for the formation of the belief by the Assessing Officer had a rational connection with or relevant bearing on the formation of belief that there had been escapement of the income of the assessee from assessment in the particular year because of his failure to disclose fully and truly all material facts. The notice of reassessment was valid. (AY. 2013-14)