Dismissing the writ petition the court held that there was proper application of mind on the part of the Assessing Officer while recording the reasons for reopening the assessments. When the return of income of both the assessees was processed under section 143(1) and not under section 143(3) the Assessing Officer was justified in arriving at the conclusion that the income had escaped assessment. The notices of reassessment were valid. (AY. 2015-16)
Hareshbhai Mathurbhai Zinzuwadia v. ACIT (2021) 438 ITR 413 /2022) 284 Taxman 220 / 215 DTR 323/ 328 CTR 931 (Guj.)(HC)/ Darshit Asokbhai Zinzuvadia v ACIT ( 2022) 215 DTR 323/ 328 CTR 931 ( Guj)( HC
S. 147 : Reassessment-With in four years-Gift by proprietor of Jewellery business to his close relatives-Relatives investing gifts in business and forming a partnership-Notice was held to be valid. [S.143 (1), 148, Art. 226]