Mamta Gupta v. NFAC (2022) 217 DTR 54 (Delhi)(HC)

S. 147 : Reassessment-After the expiry of four years-Penny stock-Information from investigation wing-Fresh material-No change of opinion-Reassessment notice is valid. [S. 148, 151, Art. 226]

Dismissing the petition the Court held that, despite of lapse of four years of a scrutiny assessment, there is fresh tangible material in the form of information of beneficiaries of bogus LTCL / STCL report prepared by the Dy. DIT (Inv) reveals that penny stock whose share price was manipulated in trade by way of a complex web of pre-arranged or artificial transactions to book long-term/short-term capital gain/loss to the beneficiaries. Assessee was involved in the trade of penny stock and had sold shares. The reassessment notice was held to be valid. (AY.2013-14)