RAJNISH PURI Vs. ASSISTANT COMMISSIONER OF INCOME TAX

JUDGEMENT

(1.) Present writ petition has been filed challenging the order dtd. 23/7/2022 passed under Sec. 148A(d) of the Income Tax Act, 1961 (hereinafter referred to as the 'Act') and the consequential notice dtd. 24/7/2022 issued under Sec. 148 of the Act for the Assessment Year 2014-15.

(2.) In the present matter, the assessment of the Assessee was reopened on the basis of information uploaded on INSIGHT portal stating that search under Sec. 132 of the Act had been conducted on 11/9/2018 in the case of Jignesh Shah and Sanjay Shah of Ahmedabad and the search had resulted in seizure of unaccounted cash of Rs.19.37 crores (relating to accommodation entries and commission earned thereon), along with incriminating digital as well as documentary evidences. As per the impugned Order, the Assessee, Shri Rajnish Puri, was found to be a beneficiary of accommodation entry of fictitious loan of Rs.63,06,250.00 during Financial Year 2013-14.

(3.) Learned counsel for the Petitioner contends that the Petitioner has consistently stated during the proceedings that he has not entered into any transaction with Mr. Jignesh Shah or Mr. Sanjay Shah, much less any loan transaction and that the Petitioner is ready to file an affidavit in this regard. He contends that the information on which the reassessment proceeding had been initiated was incorrect and the assumption of jurisdiction was completely flawed.