Reynolds Shirting Ltd. v. ACIT (2022)285 Taxman 554 (Bom) (HC)

S.147: Reassessment – After the expiry of four years – Cash credits – Information received from Director (Investigation ) –Bogus suspicious transaction – Fishing enquiry – Reassessment notice is quashed . [ S. 68, 148 , Art , 226 ]

Assessee-company filed its return of income which was accepted and an assessment was completed . The  notice was issued for reopening of assessment . In the reasons recorded merely indicated information received from Director (Investigation) about certain entity entering into suspicious transactions and material was not further linked by any reason to come to conclusion that assessee had indulged in any activity which could give rise to reason to believe on part of Assessing Officer that income of assessee chargeable to tax had escaped assessment. On writ the court held that  this was an evidence of a fishing enquiry and not a reasonable belief that income chargeable to tax had escaped assessment . Re assessment notice is quashed ..  (