Allowing the petition the Court held  that the assessee had already made available shareholding agreement with SHPL and SCPL and same had been examined by Assessing Officer, who also in fact, did not accept assessee’s explanation and added amount of Rs. 3 crores to assessee’s income.  The  addition was deleted by Commissioner (Appeals) and order of Commissioner (Appeals) had been upheld by Tribunal. There was no failure on part of assessee to truly and fully disclose material facts. Even assuming that assessee should have disclosed that these were bogus or accommodation entries, still there was nothing on record to indicate that assessee was aware that these were bogus shares capital/premium from bogus paper companies, viz., SHPL and SCPL and were accommodation entries. Notice issued under section 148 as well as assessment order  was  quashed and set aside.  (AY. 2012-13)