PRATIBHA FINVEST P.LTD Vs. ITO WARD

JUDGEMENT

(1.) The assessee is aggrieved by an order of the Income Tax Appellate Tribunal (ITAT) dated 10.01.2011; it seeks to appeal under Section 260A of the Income Tax Act. The question of law sought to be urged in the said appeal is:

(2.) In the writ petition, the order of the ITAT, refusing to entertain the appellant's application under Section 254(2) and rectify its order made in the appeal, has been impugned.

(3.) The brief facts of the case are that pursuant to search operations conducted on certain third parties, characterized as "accommodation entry providers"/"bogus share applicants", a report was furnished by the Investigation Wing of the Income Tax Department to various AOs. Relying upon one of these reports, the AO, in the present appellant's case, issued notice under Section 147, seeking to reopen the assessment proceedings. The relevant part of the notice, recording the AO's "reasons to believe" why reassessment was necessary states as follows: