AO must be satisfied that accommodation entries exist before proceeding u/s 148

Sonansh Creations Pvt Ltd Vs ACIT And Anr. (Delhi High Court)

Conclusion: Where assessee had produced ledger accounts, AO did not have any material to substantiate that deposits aggregating ₹66,44,134/- were made in assessee’s bank account to contradict the same. Clearly, AO was required to be satisfied that such entries exists particularly where assessee had produced its accounts to show that the value of transactions was not as stated in the notice under Section 148A(b).

Held: AO had issued a notice under Section 148 calling upon

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