Dismissing the petition the Court held that the AO had filed a detailed affidavit and had also placed on record the appraisal report on the basis of which he had formed the opinion that income chargeable to tax had escaped assessment in the case of the assessee. A perusal of the appraisal report revealed that there was sufficient material for the Assessing Officer to form the belief that income chargeable to tax had escaped assessment. The material also specifically referred to the assessee, which clearly established a link between the materials relied upon and the assessee. Accordingly the Court held that the reassessment proceedings were valid. (AY. 2011-12)
Purnima Komalkant Sharma v. Dy. CIT (2019)419 ITR 361 (Guj.)(HC)
S. 147 : Reassessment-Bogus transactions-Accommodation entries-bogus long term capital gains-Sale of shares-Report by investigation wing–Search of third person-Reasons can be explained further in affidavit-Reasons Can Be Explained Further In Affidavit—Notice of reassessment is held to be valid. [S. 45, 148, 153A(1)(b), Art. 226]