Reopening Assessment Under Section 147 Valid When AO Discovers New Facts About Bogus Purchases and Investments

ITAT upheld the reopening of assessment under s.147 as it was based on new facts not previously available to the AO, rejecting assessee's claim of mere "change of opinion." Regarding bogus purchases from six entities, ITAT confirmed CIT(A)'s approach of quantifying profit at 10% GP rate (less 1.53% already disclosed), sustaining addition of Rs. 1,22,08,002. CIT(A) reasonably estimated profits based on prevailing GP rates in rice miller/trader business for goods procured from grey market rather than bogus entities. On unaccounted investments, ITAT affirmed AO's addition based on "peak purchase" amount appearing in bogus concern's account, considering it represented unexplained investment in bogus billing operations. .....

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