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67. [2025] 126 ITR(T) 290 (Mumbai - Trib.)
Vinod Kumar Kasturchand Golechha vs. ITO
ITA NO:. 1966 & 1967 (MUM.) OF 2024
A.Y.: 2009-10 & 2010-11 DATE: 17.12.2024
Sec. 143(2) r.w.s. 147
Non-issuance of notice under section 143(2) after filing of return in response to notice under section 148 – Reassessment proceedings held invalid
FACTS:
The assessee was engaged in the business of import, export, and trading of cut and polished as well as rough diamonds.
Pursuant to a search and seizure action carried out on 03.10.2013 in the case of Shri Bhanwarlal Jain and his group concerns, information was received by the Department that various entities managed by the said group were engaged in providing accommodation entries through benami concerns. Based on this information, the assessee’s case was reopened for A.Ys. 2009–10 and 2010–11 on the allegation that he had obtained accommodation purchase entries from the said group concerns aggregating to ₹8.72 crore.
Notices under section 148 were iss
