Allowing the appeal of the Revenue the Court held that the Commissioner (Appeals) during the scrutiny proceedings and remand proceedings none of the directors of the companies appeared before the Assessing Officer and the Assessing Officer rightly identified nine shell companies who were providing bogus purchase bills and accordingly held that the assessee had deposited its own unaccounted cash in the bank account and confirmed the findings. The Tribunal failed to examine any of the factual details which had been brought out by the Assessing Officer as well as the Commissioner (Appeals). The Tribunal was in error in setting aside the order of the Commissioner (Appeals). The notice of reassessment was valid. (AY.2011-12)
PCIT v. Arshia Global Tradecom Pvt. Ltd. (2023)455 ITR 686/154 taxmann.com 47 / 333 CTR 806(Cal)(HC) Editorial: Order in Arshia Global Tradecom Pvt. Ltd v.ACIT (2020) 84 ITR 64 (SN) (Kol)(Trib), reversed.
S. 147 : Reassessment–After the expiry of four years-Report from investigation wing after scrutiny assessment-Shell companies-Deposited unaccounted cash in bank accounts-Prima facie material giving rise to belief sufficient-Notice valid.[S.143(3), 148]