Geetaben Dineshchandra Gupta v. ITO (2021) 208 DTR 154 / 129 taxmann.com 346 / (2022)441 ITR 698 (Guj.)(HC)

S. 147 : Reassessment-After the expiry of four years-Accommodation entries-Purchase and sales-Commission income was not disclosed-Information from investigation Wing-Direct nexus and live link-Reassessment notice was held to be valid. [S. 148, Art. 226]

Dismissing the petition the Court held that from inquiry/investigation by Investigation Wing, some tangible material was found to substantiate fact that assessee was provider of accommodation entries and that, income from commission, was not disclosed in return and, thus, there was direct nexus/live link between material coming to notice of Assessing Officer and that for formation of his belief that there had been escapement of income of assessee because of his failure to disclose fully and truly all material facts. Reassessment notice was held to be justified. (AY. 2012-13)