Interesting judgement: Reassessment–Notice under section 148–Based on information coming from investigation Wing Facts:

Notice under section 148




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Sabh Infrastructure Ltd. v. Asstt. CIT

 

Reassessment–Notice under section 148–Based on information coming from investigation Wing

Facts:

AO issued notice under section 148 on the ground that based on information emanating from investigation wing assessee was suspected to have circulated its unaccounted income in the guise of receipt of share capital from certain entities not in actual existence.

Held:

Reasons recorded for reopening failed to mention as to what facts or information was withheld by assessee. Merely relying on information coming from investigation wing was insufficient for reopening as it was evident that AO failed to make further inquiry in the matter. Accordingly, reassessment notice based on mere conjectures or surmise was not sustainable.

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