Court Rules AO Needs Evidence, Not Allegations, to Reopen Assessment; Notices u/ss 148, 148A(b), 148A(d) Nullified.

AO issued notice u/s 148A(b) alleging petitioner received accommodation entries from entities controlled by Sh. Joginder Pal Gupta. Petitioner denied receiving any amount and provided bank account details. HC held AO cannot reopen assessment without examining material to establish petitioner received entries in bank accounts. Mere allegation of accommodation entries without substantiating material is insufficient. AO must ascertain basic facts are sustainable before reopening assessment. Impugned notices u/s 148, 148A(b) and order u/s 148A(d) set aside by HC. .....

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