222 Taxman 15 (Gujarat)(MAG.), Principal Commissioner of Income-tax-4 v. G & G Pharma India Ltd.

384 ITR 147High Court2016#289 most cited

What is 222 Taxman 15 (Gujarat)(MAG.), Principal Commissioner of Income-tax-4 v. G & G Pharma India Ltd. authority for?

An assessment can be reopened if there is tangible material indicating escapement of income, demonstrating a live link between the material and the reasons recorded for reopening. The Assessing Officer must apply their mind to the material facts, and the sanction under section 151 should not be based on borrowed satisfaction.

274

judgments rely on this decision, according to BharatTax’s citation analysis of 367,154 Indian tax judgments — from 2015 to 2026.

Also referred to as

Principal Commissioner of Income-tax-4 v. G & G Pharma India Ltd. · section 147 · section 148 · section 151 · section 143(3) · reason to believe · tangible material · live link · borrowed satisfaction · non-application of mind · escapement of income

Sections most often in play

Section 147Section 148Section 143(3)Section 151Section 68Section 133(6)Section 142(1)Section 143(1)

Issues it is cited on

sanction under section 151section 151(1)live linkborrowed satisfactionmaterial facts necessary for assessmentsection 148(2)non application of mindtangible materialkelvinatorreason to believenon-application of mindescapement of income

Judgments citing 222 Taxman 15 (Gujarat)(MAG.), Principal Commissioner of Income-tax-4 v. G & G Pharma India Ltd.

Natrajan Monie, Gurgaon vs. ITO, Gurgaon

In the result, appeal of the Assessee allowed

ITA 1817/DEL/2017[2011-12]Status: DisposedITAT Delhi07 Dec 2020AY 2011-12

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

For Appellant: Shri Kapil Goel, AdvocateFor Respondent: Ms. Rinku Singh, Sr.DR
Section 147Section 148

…escaped assessment mere reproduction of investigation report in reasons recorded absence of link between tangible material and formation of ceding illegal Income Tax Act, 1961, Sec.147, 148" 6.8. In the case of Pr. CIT vs., G And G Pharma India Ltd., [2016] 384 ITR 147 (Del.), the Hon’ble Delhi High Court held as under : “Reassessment condition precedent application of mind by assessing officer to materials prior to forming reason to believe income has escaped assessment - No independent application of mind to information received from Directorate of Investigation and no prima facie opinion formed- reassessmen…

Khetan Twist Net P.Ltd, Mumbai vs. ITO 12(3)(2), Mumbai

In the result, the appeal is partly allowed

ITA 3031/MUM/2017[2007-08]Status: DisposedITAT Mumbai23 Nov 2020AY 2007-08

Bench: Shri Saktijit Dey () & Shri N.K. Pradhan () Assessment Year: 2007-08

For Appellant: Smt. Arati Vissanji, ARFor Respondent: Shri Sunil Deshpande, DR
Section 132Section 132(4)Section 143(1)Section 143(3)Section 148

…hat the copy of statement recorded was not provided to the assessee. Thus it is stated that the notice u/s 148 issued by the AO, reopening the assessment is invalid. In this regard, reliance is placed on the decision in Pr. CIT v. G&G Pharma India Ltd. (2016) 384 ITR 147 (Delhi). 6. On the other hand, the Ld. Departmental Representative (DR) submits that the original return of income was processed u/s 143(1) of the Act and on the basis of information received from the Director General of Income Tax (Inv.), the AO has rightly reopened the assessment. 7. We have heard the rival submissions and perused the relevan…

Akik Marketing India Pvt Ltd, New Delhi vs. ITO Ward - 2(1), New Delhi

The appeal of the assessee is allowed on this legal issue which is contested by the assessee in Ground Nos

ITA 8884/DEL/2019[2011-12]Status: DisposedITAT Delhi06 Nov 2020AY 2011-12

Bench: Shri G.S. Pannua N D Ms. Suchitra Kamble

For Appellant: Shri Shantanu Jain, C. AFor Respondent: Shri R. K. Gupta, Sr. D. R
Section 139(1)Section 147Section 148Section 151Section 68Section 69

…tigation wing on seized material that too which is not found from assessee’s possession is submitted that it cannot be made as valid basis to infer income escaping assessment u/s 148 of the Act. The Ld. AR relied upon the following decisions: i) G & G Pharma 384 ITR 147 (Del) ii) Meenakshi Overseas 395 ITR 677 (Del) iii) Sarthak Securities Co. (P) Ltd. vs. ITO (2010) 47 DTR 201 (Del) The Ld. AR further submitted that the Assessing Officer has recorded reasons just for verification and as such the reasons recorded are reasons to suspect, which are not valid in the eyes of law as proceedings cannot be initiated…

M/S Century Fiscal Services Ltd., Ludhiana vs. ITO, W-5(1), Ludhiana

Appeal of the Assessee is allowed in above terms

ITA 1204/CHANDI/2018[2009-10]Status: DisposedITAT Chandigarh28 Oct 2020AY 2009-10

Bench: Shri Sanjay Garg & Smt.Annapurna Guptaआयकर अपील सं./ Ita No.1204/Chd/2018 िनधा"रण वष" / Assessment Year : 2009-10

For Appellant: Shri Ashwani Kumar, CAFor Respondent: Smt. Meenakshi Vohra, Addl. CIT
Section 143(1)Section 143(3)Section 147Section 148Section 250(6)Section 68Section 69Section 69C

…decision of the ITAT Delhi Bench in the case of M/s Rajshikha Enterprises Pvt. Ltd. (supra) ,is apt, wherein the aforesaid proposition of law was upheld relying on decisions of the Hon’ble Delhi High Court in the case of CIT Vs G & G Pharma India Ltd.( 2016) 384 ITR 147 & Pr.CIT Vs. Meenakshi Overseas Pvt. Ltd. (2017) 395 ITR 677 which held that while report of the Investigation Wing might constitute material for the AO forming reasons to believe ,the process of arriving at such satisfaction could not be a mere repetition of the report of investigation. In the present case on perusing the contents of the reaso…

Vrc Township P Ltd., Delhi vs. ITO, New Delhi

In the result, appeal of the Assessee allowed

ITA 1503/DEL/2017[2007-08]Status: DisposedITAT Delhi14 Oct 2020AY 2007-08

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

For Appellant: Shri Suresh K. Gupta, C.AFor Respondent: Ms. Shalini Verma, Sr. D.R
Section 143(1)Section 147Section 148Section 151Section 68

…report in reasons recorded absence of link between tangible material and formation of ceding illegal Income Tax Act, 1961, Sec.147, 148" 39 ITA.No.1503/Del./2017 VRC Township P. Ltd., Delhi. 3.3. In the case of Pr. CIT vs., G And G Pharma India Ltd., [2016] 384 ITR 147 (Del.), the Hon’ble Delhi High Court held as under : “Reassessment condition precedent application of mind by assessing officer to materials prior to forming reason to believe income has escaped assessment - No independent application of mind to information received from Directorate of Investigation and no prima facie opinion formed- reassessmen…

M/S. Shree Balkishan Agarwal Glass Industries Ltd., Delhi vs. DCIT, New Delhi

In the result, the appeal filed by the assessee is allowed

ITA 5798/DEL/2016[2005-06]Status: DisposedITAT Delhi18 Sept 2020AY 2005-06

Bench: Shri R.K. Panda & Ms Suchitra Kambleassessment Year: 2005-06 Shree Balkishan Agarwal Glass Vs Dcit, Industries Ltd., Circle-8(1), C/O Sarvam & Associates, New Delhi. 403, Klj Tower North, B-5, Netaji Subhash Place, District Centre, Pitampura, Delhi. Pan: Aabcs2870C (Appellant) (Respondent) Assessee By : Shri Suresh Gupta, Ca Revenue By : Shri Saras Kumar, Sr. Dr Date Of Hearing : 26.08.2020 Date Of Pronouncement : 21.09.2020 Order Per R.K. Panda, Am:

For Appellant: Shri Suresh Gupta, CAFor Respondent: Shri Saras Kumar, Sr. DR
Section 139Section 142(1)Section 143(1)Section 147Section 148

…assessment proceedings cannot be initiated on the basis of direction of the Investigation Wing and the AO has to apply his independent mind:- i) Pr. CIT vs. RMG Polyvinyl (I) Ltd., (201 7) 396 ITR 5 (Del.) Dated: 07.07.2017; ii) Pr. CIT v.G&G Pharma India Ltd 384 ITR 147 (Del.); iii) CIT vs Independent Media Pvt Ltd in ITA 108/2015 (Del); iv) Signature Hotels P. Ltd. Vs. ITO - [2011 ] 338 ITR 0051 (Del); v) Pr. CIT vs. Meenakshi Overseas Pvt. Ltd. 395 ITR 677 (Del); vi) CIT Vs. SFIL Stock Broking Ltd., 325 ITR 285 (Del); vii) Sarthak Securities Co. P. Ltd. Vs. ITO 329 ITR 110 (Del); viii) CIT Vs. Supreme Polyprop…

Sourav Jindal, Faridabad vs. ITO Ward - 2(4), Faridabad

In the result, ITA.No.7376/Del

ITA 7378/DEL/2019[2011-12]Status: DisposedITAT Delhi10 Sept 2020AY 2011-12

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

Section 142(1)Section 147Section 148

…t of the A.O. to reopen the assessment. In support of his contention, he has relied upon Judgments of the Hon’ble Delhi High court in the cases of RNG Polyvinyle (I) Ltd., 396 ITR 5 (Del.), Meenakshi Overseas Pvt. Ltd., 395 ITR 677 (Del.) and GNG Pharma India 384 ITR 147 (Del.). He has submitted that since A.O. has admittedly did not confront any material supplied by the Investigation Wing to assessee, despite assessee made a specific request and also requested to allow cross-examination of statement of Shri Pramod Kumar Jindal and others, therefore, such material cannot be used in evidence against the assessee.…

Gourav Aggarwal, Faridabad vs. ITO Ward - 1(3), Faridabad

In the result, ITA.No.7376/Del

ITA 7377/DEL/2019[2011-12]Status: DisposedITAT Delhi10 Sept 2020AY 2011-12

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

Section 142(1)Section 147Section 148

…t of the A.O. to reopen the assessment. In support of his contention, he has relied upon Judgments of the Hon’ble Delhi High court in the cases of RNG Polyvinyle (I) Ltd., 396 ITR 5 (Del.), Meenakshi Overseas Pvt. Ltd., 395 ITR 677 (Del.) and GNG Pharma India 384 ITR 147 (Del.). He has submitted that since A.O. has admittedly did not confront any material supplied by the Investigation Wing to assessee, despite assessee made a specific request and also requested to allow cross-examination of statement of Shri Pramod Kumar Jindal and others, therefore, such material cannot be used in evidence against the assessee.…

Hanuman Prasad Aggarwal, Faridabad vs. ITO Ward - 1(3), Faridabad

In the result, ITA.No.7376/Del

ITA 7376/DEL/2019[2011-12]Status: DisposedITAT Delhi10 Sept 2020AY 2011-12

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

Section 142(1)Section 147Section 148

…t of the A.O. to reopen the assessment. In support of his contention, he has relied upon Judgments of the Hon’ble Delhi High court in the cases of RNG Polyvinyle (I) Ltd., 396 ITR 5 (Del.), Meenakshi Overseas Pvt. Ltd., 395 ITR 677 (Del.) and GNG Pharma India 384 ITR 147 (Del.). He has submitted that since A.O. has admittedly did not confront any material supplied by the Investigation Wing to assessee, despite assessee made a specific request and also requested to allow cross-examination of statement of Shri Pramod Kumar Jindal and others, therefore, such material cannot be used in evidence against the assessee.…

Narender Kumar Gupta, New Delhi vs. ITO Ward-2(1), Faridabad

In the result, ITA.No.7376/Del

ITA 7375/DEL/2019[2011-12]Status: DisposedITAT Delhi10 Sept 2020AY 2011-12

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

Section 142(1)Section 147Section 148

…t of the A.O. to reopen the assessment. In support of his contention, he has relied upon Judgments of the Hon’ble Delhi High court in the cases of RNG Polyvinyle (I) Ltd., 396 ITR 5 (Del.), Meenakshi Overseas Pvt. Ltd., 395 ITR 677 (Del.) and GNG Pharma India 384 ITR 147 (Del.). He has submitted that since A.O. has admittedly did not confront any material supplied by the Investigation Wing to assessee, despite assessee made a specific request and also requested to allow cross-examination of statement of Shri Pramod Kumar Jindal and others, therefore, such material cannot be used in evidence against the assessee.…

Garima Aggarwal, Faridabad vs. ITO Ward - 1(3), Faridabad

In the result, ITA.No.7376/Del

ITA 7374/DEL/2019[2011-12]Status: DisposedITAT Delhi10 Sept 2020AY 2011-12

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

Section 142(1)Section 147Section 148

…t of the A.O. to reopen the assessment. In support of his contention, he has relied upon Judgments of the Hon’ble Delhi High court in the cases of RNG Polyvinyle (I) Ltd., 396 ITR 5 (Del.), Meenakshi Overseas Pvt. Ltd., 395 ITR 677 (Del.) and GNG Pharma India 384 ITR 147 (Del.). He has submitted that since A.O. has admittedly did not confront any material supplied by the Investigation Wing to assessee, despite assessee made a specific request and also requested to allow cross-examination of statement of Shri Pramod Kumar Jindal and others, therefore, such material cannot be used in evidence against the assessee.…

Sheela Aggarwal, Faridabad vs. ITO Ward - 2(3), Faridabad

In the result, ITA.No.7376/Del

ITA 7373/DEL/2019[2011-12]Status: DisposedITAT Delhi10 Sept 2020AY 2011-12

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

Section 142(1)Section 147Section 148

…t of the A.O. to reopen the assessment. In support of his contention, he has relied upon Judgments of the Hon’ble Delhi High court in the cases of RNG Polyvinyle (I) Ltd., 396 ITR 5 (Del.), Meenakshi Overseas Pvt. Ltd., 395 ITR 677 (Del.) and GNG Pharma India 384 ITR 147 (Del.). He has submitted that since A.O. has admittedly did not confront any material supplied by the Investigation Wing to assessee, despite assessee made a specific request and also requested to allow cross-examination of statement of Shri Pramod Kumar Jindal and others, therefore, such material cannot be used in evidence against the assessee.…

Meena Gupta, Faridabad vs. ITO Ward - 1(5), Faridabad

In the result, ITA.No.7376/Del

ITA 7372/DEL/2019[2011-12]Status: DisposedITAT Delhi10 Sept 2020AY 2011-12

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

Section 142(1)Section 147Section 148

…t of the A.O. to reopen the assessment. In support of his contention, he has relied upon Judgments of the Hon’ble Delhi High court in the cases of RNG Polyvinyle (I) Ltd., 396 ITR 5 (Del.), Meenakshi Overseas Pvt. Ltd., 395 ITR 677 (Del.) and GNG Pharma India 384 ITR 147 (Del.). He has submitted that since A.O. has admittedly did not confront any material supplied by the Investigation Wing to assessee, despite assessee made a specific request and also requested to allow cross-examination of statement of Shri Pramod Kumar Jindal and others, therefore, such material cannot be used in evidence against the assessee.…

O.P.Yadav, New Delhi vs. DCIT, Central Circ Le-15, New Delhi

In the result, the appeal filed by the assessee is dismissed

ITA 5523/DEL/2018[2000-01]Status: DisposedITAT Delhi10 Sept 2020AY 2000-01

Bench: Shri H.S. Sidhu & Shri O.P. Kant

Section 133(6)Section 143(3)Section 144Section 147Section 148Section 158B

…enlisted below. i) Delhi high court decision in case of RMG Polyvinyl 396 ITR 5; ii) High Court of Delhi in the case of PCIT vs. Meenakshi Overseas P. Ltd. 395 ITR 677 (Del); iii) High Court of Delhi in the case of PCIT vs. G&G Pharma India Ltd. reported in 384 ITR 147 (Del); On basis of above discussion we make a humble prayer for i) admission of our legal and jurisdictional additional ground and ii) allowing our appeal by accepting our additional ground in toto and iii) quash the orders passed by Ld AO and Ld CIT-A. 3. In the additional grounds, the assessee has challenged reassessment proceeding on the groun…

Aero Dealcomm Pvt. Ltd., Kolkata vs. I.T.O., Ward-4(3), Kolkata

ITA 2484/KOL/2019[2009-10]Status: DisposedITAT Kolkata29 May 2020AY 2009-10

Bench: Sri J. Sudhakar Reddy, Hon’Ble) Assessment Years: 2009-10 Aereo Dealcomm Pvt. Ltd………….………...........................................................……………….…......Appellant C/O. S.N. Ghosh & Associates, Advocates 2, Garstin Place 2Nd Floor Suite No. 203 Off Hare Street Kolkata West Bengal – 700 001 [Pan : Aacca 5934 G] Vs. Income Tax Officer, Ward-4(3), Kolkata…………………..……………….............….……....…....Respondent Appearances By: Shri Somnath Ghosh, Advocate & Shri M. Jhawar, Fca, Appeared On Behalf Of The Assessee. Shri Jayanta Khanra, Jcit Sr. D/R, Appearing On Behalf Of The Revenue. Date Of Concluding The Hearing : February 26Th, 2020 Date Of Pronouncing The Order : May 29Th, 2020 Order Per J. Sudhakar Reddy, Am :-

Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 250Section 68

…is bad in law :-  PCIT vs. Meenakshi Overseas P. Ltd. ( PCIT vs. Meenakshi Overseas P. Ltd. (2017) 395 ITR 677 (Del.) 2017) 395 ITR 677 (Del.)  PCIT vs. RMG P PCIT vs. RMG Polyvinyl (I) Ltd. (2017) 396 ITR 5 (Del.)  PCIT vs. G & G Pharma India Ltd. (2016) 384 ITR 147 (Del.) PCIT vs. G & G Pharma India Ltd. (2016) 384 ITR 147 (Del.) PCIT vs. G & G Pharma India Ltd. (2016) 384 ITR 147 (Del.) 4.1. He further argued that He further argued that, the letter of the DCIT, Hqs.-1, Kolkata, on behalf of on behalf of the ld. Pr. CIT-1, Kolkata addressed addressed to the Addl. CIT/Jt. CIT Range to the Addl. CIT/Jt. CIT R…

Subodh Chandra Das, Hooghly vs. I.T.O., Ward-23(3), Hooghly

In the result, both the appeals of the assessee are allowed

ITA 2247/KOL/2019[2012-13]Status: DisposedITAT Kolkata04 Mar 2020AY 2012-13

Bench: Sri J. Sudhakar Reddy, Hon’Ble) Ita No. 2246 & 2247/Kol/2019 Assessment Years: 2011-12 & 2012-13

Section 147Section 148Section 250Section 68

…s approval. Therefore, the proceedings under section 148 were to be quashed. 14. The Hon’ble Delhi High Court in the case of The Hon’ble Delhi High Court in the case of Pr. CIT vs. G & G Pharma India Ltd. Pr. CIT vs. G & G Pharma India Ltd. reported in [2016] 384 ITR 147 (Del.) [2016] 384 ITR 147 (Del.) held as follows:- “that after setting out four entries, stated to have been received by the assessee on a single that after setting out four entries, stated to have been received by the assessee on a single that after setting out four entries, stated to have been received by the assessee on a single date, i.e., 10…

Subodh Chandra Das, Hooghly vs. I.T.O., Ward-23(3), Hooghly

In the result, both the appeals of the assessee are allowed

ITA 2246/KOL/2019[2011-12]Status: DisposedITAT Kolkata04 Mar 2020AY 2011-12

Bench: Sri J. Sudhakar Reddy, Hon’Ble) Ita No. 2246 & 2247/Kol/2019 Assessment Years: 2011-12 & 2012-13

Section 147Section 148Section 250Section 68

…s approval. Therefore, the proceedings under section 148 were to be quashed. 14. The Hon’ble Delhi High Court in the case of The Hon’ble Delhi High Court in the case of Pr. CIT vs. G & G Pharma India Ltd. Pr. CIT vs. G & G Pharma India Ltd. reported in [2016] 384 ITR 147 (Del.) [2016] 384 ITR 147 (Del.) held as follows:- “that after setting out four entries, stated to have been received by the assessee on a single that after setting out four entries, stated to have been received by the assessee on a single that after setting out four entries, stated to have been received by the assessee on a single date, i.e., 10…

Akg Securities & Consulting Ltd, New Delhi vs. ITO Ward - 1(1), New Delhi

In the result, the Appeal filed by the Assessee stands allowed

ITA 4395/DEL/2019[2010-11]Status: DisposedITAT Delhi27 Feb 2020AY 2010-11

Bench: Shri H.S. Sidhu & Shri N.K. Billaiyaassessment Year : 2010-11

For Appellant: Mr. Rohit Tiwari, Adv. & Sh. VinjayFor Respondent: Sh. S.N. Pandey, Sr. DR
Section 143(3)Section 147Section 148Section 250

…Co. (2011) 197 Taxman 202 (SC); Hon’ble Delhi High Court decisions in the case of Pr. CIT vs. RMG Polyvinyls (I) Ltd. (2017) 83 taxmann.com 348 (Delhi); Pr. CIT vs. Meenakshi Overseas P Ltd. vs. ITO 395 ITR 677 (Del.) and Pr. CIT vs. G&G Pharma India Ltd. 384 ITR 147 (Del.). 3.1 Ld. Counsel for the assessee placed the copy of reasons recorded by the AO and approval granted by the Pr. CIT, Delhi-1, New Delhi wherein, he has granted the approval by only mentioning that “I am satisfied”, which shows that Ld. Pr. CIT, Delhi-1, New Delhi has not recorded proper satisfaction and without application of mind gave…

Arina Grover, New Delhi vs. ACIT, Circle-45(1), New Delhi

In the result, the Appeal filed by the Assessee stands partly allowed

ITA 9316/DEL/2019[2008-09]Status: DisposedITAT Delhi20 Feb 2020AY 2008-09

Bench: Shri H.S. Sidhuassessment Year : 2008-09 M/S Arina Grover, Vs. Acit, Circle 45(1), D-25, 2Nd Floor, New Delhi Ajay Enclave, New Delhi – 110 027 (Pan: Akepg0821F) (Appellant) (Respondent)

For Appellant: Sh. Rohit Tiwari, Advocate & Sh. VinayFor Respondent: Sh. Pradeep Singh Gautam, Sr.DR
Section 139Section 143(1)Section 143(3)Section 147Section 148

…ion Co. (2011) 197 Taxman 202 (SC); Hon’ble Delhi High Court decisions in the case of Pr. CIT vs. RMG Polyvinyls (I) Ltd. (2017) 83 taxmann.com 348 (Delhi); Pr. CIT vs. Meenakshi Overseas P Ltd. vs. ITO 395 ITR 677 (Del.) and Pr. CIT vs. G&G Pharma India Ltd. 384 ITR 147 (Del.). 3.1 Secondly, he drew my attention towards Page No. 40-42 of Assessee’s Paper Book which is a copy of the reasons recorded by the AO and approval granted by the Addl. CIT, Range-45, New Delhi, wherein he has granted the approval by mentioning that “After perusing the reasons given above I am satisfied that it is a fit case for issue of n…

M/S. Bull Riders Financial Services (P) Ltd., New Delhi vs. ITO, Ghaziabad

In the result, appeal of the Assessee allowed

ITA 1891/DEL/2017[2005-06]Status: DisposedITAT Delhi10 Feb 2020AY 2005-06

Bench: Shri Bhavnesh Saini & Shri R.K. Panda

For Appellant: Shri Somil AgarwalFor Respondent: Shri S.L. Anuragi, Sr. D.R
Section 143(3)Section 147Section 148Section 151Section 68

…I) Ltd., 396 ITR 5 (Del.), Pr. Commissioner of Income Tax vs., Meenakshi Overseas (P) Ltd., 395 ITR 677 (Del.) and Pr. 20 ITA.No.1891/Del./2017 M/s. Bull Riders Financial Services (P) Ltd., Ghaziabad, Uttar Pradesh. CIT vs., G And G Pharma India Ltd., [2016] 384 ITR 147 (Del.) and Sarthak Securities Co. (P) Ltd., 329 ITR 110 (Del.). 5.7. The above discussion would make it clear that the A.O. herself has not recorded any reasons for reopening of the assessment. No details or evidence of receiving accommodation entries were available to the A.O. on the day of issue of notice under section 148 on 29.03.2012. The A…