The AO issued reassessment notice under S.  148 observing that the authorised capital of the assessee-company was Rs. 20 lakh and issued capital was Rs. 1 lakh. The balance capital to be issued was Rs. 19 lakh. The assessee-company received Rs. 87 crores as share application money against the pending share capital of Rs. 19 lakh meaning that the assessee was getting a premium of Rs. 45.69 lakhs. The share premium was 457 times the face value of Rs. 10 each. The financials of the assessee-company did not support such high valuation. Accordingly the transactions with respect to credits of Rs. 87 crores was not genuine which is the basis of reason for formation of belief that the income had been escaped assessment. Dismissing the petition the Court held that,  the reassessment notice in this case was clearly warranted. Though the assessee had sought to explain that the share application amounts were received and later the shareholding rights were transferred by Anjali Singh to his family trust. The identity of Anjali Singh was known, however, looking at the transaction  were apparently not established. The revenue was justified in issuing the impugned notice. (AY. 2012-13)