Madhav Gems Pvt. Ltd. v. ITO (2021)434 ITR 684 / 200 DTR 297(2022) 325 CTR 489 (Guj.)(HC)

S. 147 : Reassessment-After the expiry of four years-Accommodation entries-Policed diamonds-Subsequent information-Transaction disclosed in the original assessment proceedings were not valid-Sanction obtained-Reassessment was held to be valid. [S. 132, 148, 151, Art. 226]

Dismissing the petition the Court held that the subsequent information that transaction disclosed in the original assessment proceedings were not valid  and the  Assessing Officer presented the reasons recorded for approval of the Principal Commissioner in the prescribed format through the Additional Commissioner. Both officers had perused the reasons recorded and opined that it was a fit case to issue notice under section 148. There was compliance with section 151. The notice was valid. (AY. 2012-13)