On a writ petition, the High Court quashed the notice and held that the Assessing Officer had assumed jurisdiction on the basis of borrowed satisfaction without there being any live link between the information and the material on record and had issued notice for making a fishing inquiry which was not permissible. SLP of revenue dismissed.(AY. 2014-15 )
Dy. CIT v. Rakesh Ramanlal Shah (2025) 477 ITR 296 (SC) Editorial : Rakesh Ramanlal Shah. v. Dy. CIT 2024] 165 taxmann.com 364 / (2025) 477 ITR 289 (Guj)(HC)
S. 147 : Reassessment-Capital gains-Information from investigation unit – Penny stock – Borrowed satisfaction- Fishing inquiry not permissible – Order of High Court quashing the notice is affirmed – SLP of revenue dismissed.[S. 10(38), 45, 148, Art. 136]