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Reopening under amended Section 147 failed where the Assessing Officer relied only on high-value bank credits and debits already recorded in the books and audited accounts. The Court held that mere volume of inter-group loan transactions, without tangible material showing escapement of income, could not justify reassessment; absence of an NBFC licence and non-charging of interest were also irrelevant on the facts. It further held that the final Section 148A order could not rest on an M2M loss allegation or bullion purchase allegation when no prior opportunity was given and no supporting material was cited. The notices under Section 148 and the orders under Section 148A(3) were quashed.
Reopening under amended Section 147 failed where the Assessing Officer relied only on high-value bank credits and debits already recorded in the books and audited accounts. The Court held that mere volume of inter-group loan transactions, without tangible material showing escapement of income, could not justify reassessment; absence of an NBFC licence and non-charging of interest were also irrelevant on the facts. It further held that the final Section 148A order could not rest on an M2M loss allegation or bullion purchase allegation when no prior opportunity was given and no supporting material was cited. The notices under Section 148 and the orders under Section 148A(3) were quashed.
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