Nothing indicated knowingly participation in sham transaction: Reopening quashed

Mukundbhai Manubhai Patel Vs ACIT (Gujarat High Court) Gujarat High Court held that the respondent officer could not have assumed jurisdiction for reopening the assessment since there was nothing which indicate that petitioner has participated knowingly in the sham transaction. Accordingly, order is quashed and set aside. Facts- The petitioner filed Return of Income for Assessment Year 2018-19 on 18.09.2018 offering total income at Rs.1,67,40,840/-. The impugned show cause notice under Section 148A(b) of the Act was issued on 23.03.2022 by the Respondent along with the details of information...