Sairam Commercial Pvt. Ltd. v. UOI (2018) 406 ITR 281 (All) (HC)

S.147: Reassessment-After the expiry of four years- Shell companies-Search of third person revealing that transaction disclosed by Assessee during original assessment was bogus — Notice is held to be valid .[ S.148 ]

Dismissing the petition, the court held that  after conclusion of the assessment order under S .143(3) , the Assessing Officer received information that the disclosure, as made by the assessee in the return, was bogus. The material was in no way unreliable or unauthentic, inasmuch as it was on the basis of the statement of the person, running the shell company, who himself had confessed that the assessee was one of the companies which had received a sum of Rs. 14,70,15,000 as security premium during the assessment year 2008-09. The notice of reassessment was valid. (AY.2008 -09)