Reopening notice was issued on ground that an information was received that a company, namely, Panveen Trading Pvt. Ltd. was indulged in generating and selling fake invoices to various entities without physical supply of underlying goods/services for passing regular input tax credit to other business entities and that assessee was also a beneficiary of such transaction.  Assessee filed writ petition contending that it did not enter into any purchase or sale transaction with any such entities and it had also not claimed any input tax credit with respect to goods and service tax purportedly paid by said entities, thus, there was no question of escapement of income chargeable to tax by making claim of bogus expenditure in terms of bogus purchases. Dismissing the petition the Court held that  grounds which was taken by assessee in writ petition was his defence that could not be examined at stage of issuance of notice under section 148 as Assessing Authority before issuance of reopening notice had to relied upon credible information which in impugned notice had already been furnished and thereafter considering such information it had recorded a finding that it was a fit case where notice under section 148 could be issued. The Court also observed that  the assessee was unable to point out that findings which was recorded by Assessing Authority were contrary to material on record and Assessing Authority had not applied its mind or Assessing Authority had not considered reply filed by assessee.(AY. 2018-19)