Dismissing the petition the Court held that the notice was issued based on specific information which was received after the assessment, the assessment was under section 143(1) and the higher authority has granted the approval. At the stage of issuing the notice the court cannot investigate in to adequacy or sufficiency of the reasons. (AY. 2012-13)
Nishant Vilaskumar Parekh v. ITO (2021) 203 DTR 290/ ( 2022) 440 ITR 436 (Guj.)(HC)
S. 147 : Reassessment-After the expiry of four years-Penny stock-Specific information-Information wing-Approval was obtained-Reassessment notice was held to be valid. [S. 143(1), 148, Art. 226]