The Court noted that the party had already accepted that it was not engaged in real business activities. Further, the mere filing of VAT returns cannot help establish the genuineness of transactions without the VAT department making physical or spot enquiries. The parties still need to produce the relevant documents, transport details, purchase contracts or bills concerning the alleged purchases. Hence the investigation revealed that the transaction was merely accommodating entries. The AO correctly passed the order under section 148(d) and the notice for reassessment. (AY. 2014-15)