The petitioner company issued shares at face value of Rs 100 per share. Details of shares were disclosed in the return of income and specific question was raised in the course of assessment proceedings. After considering the reply the assessment was completed. The reassessment notice was issued on the ground that provision of section 56(2)(vii)(c) (ii) of the Act is attracted. On writ allowing the petition the Court held that   there was no reason or ground available with the Assessing Officer to issue notice under section 148. Issuance of notice to the assessee under section 148 was not in accordance with the first proviso to section 147 and therefore, unsustainable. The reason assigned for issuance of notice was that the transfer of shares attracted the provisions of section 56(2)(vii)(c)(ii) which provision applied to individual and Hindu undivided families. The specific provision under section 56(2)(vii) relied on by the Assessing Officer for issuance of notice would not be applicable to the assessee which was a company. (AY. 2014-15)