Assessee-company, with majority Indian shareholders, filed its return for the relevant year. Assessing Officer issued a show-cause notice dated 31-3-2025 under section 148A(1), proposing initiation of proceedings under section 148. Assessee filed a detailed reply on 17-4-2025 with documentary evidence, including bank statements, explaining transactions in question. Assessing Officer passed an order under section 148A(3) concluding that income of about Rs. 12.16 crores had escaped assessment and, on the same day, issued a notice under section 148 to reopen assessment. On writ, the Court held that the opinion for reopening was formed primarily on allegations of ‘circuitous’ transactions with related parties and inputs from a Suspicious Transaction Report (STR). However, there was no material or evidence on record suggesting escapement of income. Further, the assessee had fully disclosed income and justified the same in reply filed before authorities. Court held that since the respondent had reopened assessment merely on the basis of findings emerging from STR, without duly considering submissions and explanations tendered by the assessee and further, the respondent had neither doubted documentary evidence produced by the assessee nor pointed out any infirmity in material furnished in relation to transactions reflected in the assessee’s bank account. Accordingly, the notice and order could not be sustained and were quashed and set aside. (AY. 2021-22)