Dismissing the petition the Court held that pursuant to information received from ADIT, Kolkata ACIT, Delhi and ITO, Kolkata, Assessing Officer examined records and found that assessee had received funds to tune of Rs. 95 lakhs by way of routing funds materialized by Radha Fincom Pvt. Ltd. and Ors, which were found to be merely paper concerns having no real business and in this way, unaccounted money of assessee amounting to Rs. 95 lakhs was routed to its books of account. Said facts had not been examined by Assessing Officers during original assessment for want of full and true disclosure of facts by assessee. There being prima facie material available on record before Assessing Officer to establish that assessee had routed its own money in garb of share application money and share premium through a number of shell companies operating from Kolkata, issue of reassessment notice was justified. (AY. 2013-14)
Ambuj Foods (P) Ltd. v. PCIT (2022) 287 Taxman 490/ 212 DTR 460/ 326 CTR 352 (All.)(HC)
S. 147 : Reassessment-Share application money-Shell companies-Operating from Kolkata-Reassessment notice is valid. [S. 69A, 148, Art. 226]