Sec 147 : Reassessment Notice Validity Original Assessment without scrutiny Subsequent information from Investigation Wing of Income Tax Department that theassessee could be having undisclosed income Information considered and notice issued Notice Valid.
Held :
dismissing the petition, that the returns had been accepted without scrutiny. The Income Tax Investigation Wing had subsequently provided information about certain companies having bank accounts with a Bank in Kolkata and who were involved in giving accommodation entries of various nature to several beneficiaries including the assessee. The information supplied by the Investigation Wing to the AO formed a Prima Facie basis to enable the AO to form a belief of income chargeable to tax having escaped assessment. The AO perused the information supplied by the Investigation Wing and having formed the belief that income chargeable to tax had escaped assessment, could not be stated to have acted mechanically. Further, the mere fact that the assessee had asked for certain information from the AO, which at this stage was not supplied, would not invalidate the reasons recorded by the AO in issuing the the notice. The notice was valid.
Avirat Star Homes Venture P. Ltd. Vs ITO and others [2019] 411 ITR 321 (Bom).
