Reopening cannot be made to disallow Bogus Sales/ Purchases based on a Judgment

Saurabh Suryakant Mehta Vs ITO (Bombay High Court) In the present case, the Assessing Officer had examined the material collected by the Sales Tax Department, prima facie suggesting that the assessee had indulged into bogus billing activities without actually carrying out the purchase and sale of the commodity. It is on this basis that the notice of reopening of assessment was issued earlier and addition of Rs.2,96,284/­ was made. There are reasons recorded for issuing the impugned notice. We can gather that the Assessing Officer now believes that not mere 2.25% of the total bogus purchase of...