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TMI Blog2023 (8) TMI 966X X X X Extracts X X X X X X X X Extracts X X X X ..... s were also provided. It is also mentioned in the reply that Petitioner has accounted the bill into its books of accounts for which GST tax invoice has been submitted and the bill has been uploaded on GST portal which can be verified and Petitioner has taken credit for the same. Despite this the impugned order dated 19th April 2023 u/s 148A(d) of the Act came to be passed which defies sensibility. We are unable to fathom how just because Petitioner has accepted that it had transactions with S. K. Jewels, there could be no dispute that the amount paid to S.K. Jewels would be for taking accommodation entries. There is nothing to say why Petitioner s explanation cannot be accepted. We are also surprised that to issue such an order the PCIT ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Sr. No. Information FY Information Source Type Information Source Description Information Type Information Description Information Value 1. 2018-19 Sluspicious Transaction Report S K. Jewels PAN ADJFS0448Q 1,10,58,12,400/- 3. As per explanation 1 of section 148 of the Act, any information with the Assessing Officer in accordance with RMS formulated by the CBDT constitutes the information which suggests that income chargeable to tax has escaped assessment for the purpose of sec ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s the only place where Petitioner s submissions have been dealt with, reads as under:- 6.1 The assessee itself has accepted that it entered the transactions with the party. As per the information available, uploaded by the Investigation Wing that the assessee has made suspicious transactions such sales purchases. Since, the assessee has accepted that it had transactions with the party there is no dispute with the amount for which the assessee taken accommodative entries. Hence, based upon the above facts and circumstances the assessee s explanation cannot be accepted and it is viewed as there is an escapement of income of Rs. 1,10,58,12,400/- and this is a fit case for initiation of proceedings u/s 148A of the Act. Hence, I have reas ..... X X X X Extracts X X X X X X X X Extracts X X X X
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