Sunrise Broking Pvt. Ltd. v. ITO (2018) 400 ITR 337 (Guj) (HC)

S. 147: Reassessment —Deemed dividend – Notice based on information received from another assessee’s assessing authority was held to be valid [ S. 2(22)( e ), 143(1), 148 ]

Dismissing the petition the Court held that ; merely because the relevant material was brought to the notice of the Assessing Officer by an Assessing Officer of another assessee that would not per se vitiate his satisfaction that income chargeable to tax had escaped assessment. The return of the assessee was processed under section 143(1) without scrutiny. The reasons recorded by the Assessing Officer for issuing notice under section 148 did not lack validity so that the notice for reopening could be terminated at that stage itself on such ground.( AY. 2009-10)