The appeal of the assessee is DISMISSED
Bench: Shri Partha Sarathi Chaudhury & Shri G. D. Padmahshaliआयकर अपऩल सं. / Ita No. 956/Pun/2023 निर्धारण वर्ा / Assessment Year : 2009-10 Vilson Roofing Products Pvt. Ltd., 1St Lane, Opp. Prataprao Jagdale Hall, Rajarampuri, Kolhapur, Pin – 416 008 . . . . . . . अपऩलधथी / Appellant Pan: Aaccv0661M
201-02 (SC) examining the power of court to investigate the belief of the AO has held as under: “All that is necessary to give special jurisdiction under section 147(a) is that the Assessing Officer had when he assumed jurisdiction some prims facie grounds for thinking that there has been some non-disclosure of material facts. Whether these grounds