The assessee had filed return declaring loss for AY 2010-11 and assessment was earlier completed under section 153C r.w.s. 143(3) at nil income. Thereafter, notice under section 148 dated 31-3-2017 was issued on the basis of information received from the Director of Investigation, Kolkata that the assessee had raised share capital of Rs. 1.51 crore by issuing shares at face value of Rs. 10 and premium of Rs. 90 to certain paper/shell companies, most of which were allegedly controlled by one NKJ, an admitted accommodation entry operator. The Assessing Officer had also called upon the assessee to furnish details such as share application forms, names of allottees, number of shares allotted, breakup of face value and premium, and mode of receipt of funds, but there was no material to show that the assessee had furnished proper supporting details or answered the specific queries. On writ, the Court held that the information received from the Investigation Wing regarding bogus share capital and shell companies was germane material and had a live link with the formation of belief that income had escaped assessment. Since the assessee neither rebutted the allegations with supporting material before the Assessing Officer nor before the Court, and the statutory requirements of recording reasons, obtaining sanction and furnishing reasons were duly complied with, the reopening could not be said to be without jurisdiction. The wider post-1-4-1989 scope of section 147 permitted reopening on the basis of such tangible material. Accordingly, the writ petition was dismissed.  (AY. 2010-11)