Meghavi Minerals (P.) Ltd. v. CIT (2019) 267 Taxman 1 (Guj.)(HC)

S. 147 : Reassessment–After the expiry of four years-Information by Investigation wing–Accommodation entries-Pravin Kumar Jain-One of the beneficiary–Reassessment is held to be valid [ S.69, 132(4), 148, 151, Art. 226]

Assessment was completed u/s 143(3). After completing assessment, received information from Investigation Wing of department that search proceedings were carried out in case of Pravin Kumar Jain wherein he admitted that he was involved in providing accommodation entries to various companies and assessee was one of those beneficiary companies. On basis of aforesaid information, AO issued notice to assessee under S. 148 seeking to reopen assessment.   Assessee’s objections to initiation of reassessment proceedings were rejected. On writ dismissing the petition the Court held that since it was not a case where AO initiated reassessment proceedings on absolutely vague or unspecific information without taking pains to form his own belief in respect of material supplied by Investigation Wing, validity of impugned proceedings deserved to be upheld. (AY. 2012-13)