Dismissing the petition the Court held that the Assessing Officer was entitled to initiate reassessment proceedings on basis of tangible material which came in his hand as regards the bogus purchases. Court also held that competent Authority had given satisfaction in writing and accorded sanction under section 151 on the date of issue of notice, hence the sanction is valid in law. (AY. 2012-13)
Nisha Diamonds (P.) Ltd. v. ITO (2021) 280 Taxman 314 (Guj.)(HC)
S. 147 : Reassessment-With in four years-Accommodation entries-Hawala dealer-Bogus purchases-Recorded reason-Reassessment is valid-Approval was granted on the date of issue of notice-Sanction is valid. [S. 68, 148, 151, Art. 226]