North End Foods marketing(P) Ltd. v. Dy. CIT (2022) 220 DTR 68 / 329 CTR 788 / (2023) 146 taxmann.com 67 (Delhi)(HC)

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Beneficiary of accommodation entries-Transaction in the course of business-Writ petition was dismissed. [S. 148, 149, Art. 226]

A show cause notice was issued upon assessee to provide information regarding accommodation entries received by it from an entity, namely, STC After no reply was received, another notice was issued under section 148A(b) and reassessment proceeding was initiated. Assessee filed a writ petition against same and it was contended that said transaction was done in course of business. Dismissing the petition the court held that petition to determine disputed facts was not maintainable at this interim stage of reassessment proceedings. (AY. 2013-14)