Vijay Ramanlal Sanghvi v. ACIT (2023) 330 CTR 424/ 146 55 (Guj.)( HC)

S.147 :Reassessment – After the expiry of four years – Loan -Accommodation entries -Documents produced during assessment proceedings- No failure to disclose material facts- Notice and order disposing the objection was quashed . [S. 68, 148 , Art , 226 ]

Where it is was the case of the Assessing Officer  that the assessee was a beneficiary of accommodation entries to the tune of Rs. 2.1 crore, but however the assessee supplied all documents and information to the AO during the course of assessment proceedings such as bank statement and bank interest, then the AO cannot conduct a roving inquiry when the amount received was admittedly returned. Notice was  quashed.(AY. 2011-2012

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