Garvit Diamonds Pvt. Ltd. v. ITO (2021)435 ITR 737 / 203 DTR 34 (2022)) 325 CTR 530 (Guj.)(HC)

S. 147 : Reassessment-After the expiry of four years-Finding by Investigation Wing-Bogus transaction-Accommodation entries-No true disclosure of facts-Issue of notice is valid. [S. 148, 149, Art. 226]

Dismissing the petition the Court held that   the case of the assessee was sought to be reopened on the basis of information received from the Investigation Wing wherein, it was stated that, the agency had scrutinised selected bank account numbers of the assessee, maintained with Standard Chartered Bank and prima facie it was found that the transactions reflected in the accounts used by the assessee for layering of funds and the credit entries of Rs.51,00,000 were mere accommodation entries and the credit entries remained unexplained. The Assessing Officer had verified the information with regard to suspicious cash transactions and upon analysis of the bank statements, had seen that compared to turnover, the total income was very low, which in his opinion, was not commensurate with the profit. The facts with regard to cash transactions had not been disclosed truly and fully. The notice of reassessment was valid. (AY. 2012-13)