Dismissing the petition the Court held that the reasons assigned for the notice of reassessment showed that the Assessing Officer, based on information of suspicious transactions report from the Income-tax Officer (Inv), has verified the transactions. Notice under section 131A of the Act was also issued and statements were recorded including of one SKM. Based on the statements, the Assessing Officer recorded that the assessees obtained bogus purchase bills during the relevant period. The Revenue had placed on record copy of screen shot of Income-tax Business Application web portal in which there was mention of “print approval” against the name of respective assessee with the director identification number. The sanction or approval under section 151 of the Act issued by the competent authority in the case of the assessees would be deemed to be an authenticated document. The notice of reassessment was valid. (AY. 2016-17)
Jugal Kishore Paliwal v. JCIT (2022) 446 ITR 515 / 213 DTR 121 / 326 CTR 361 (Chhattisgarh)(HC) Saraswati Agro Industries (2022) 446 ITR 515 / 213 DTR 121 / 326 CTR 361 (Chhattisgarh)(HC) Vidhya Nagdeo (Smt.) v. JCIT (2022) 446 ITR 515 / 213 DTR 121 / 326 CTR 361 (Chhattisgarh)(HC)
S. 147 : Reassessment-Transactions discovered to be non-genuine by Income-Tax Officer (Inv)-Notice valid-Sanction-Order of sanction to be tested along with reasons for notice. [S. 131A, 148, 151, 282A, Art. 226]