Dismissing the petition the Court held that the Assessing Officer had examined the information received from the Surat wing and based on the information made inquiries and after independent application of mind, and upon due satisfaction, had reached the conclusion that the alleged transaction with A Ltd. seemed to be a bogus purchase and it was accommodation entries provided at the instance of AM and their group. After the framing of the assessment made under section 143(3) of the Income-tax Act, 1961 tangible material came into the hands of the Assessing Officer through the Investigation Wing and upon perusal thereof, he made independent inquiries and applied his mind and upon due satisfaction, he formed an opinion that the income had escaped assessment. The notice of reassessment was valid. (AY.2012-13)