https://www.taxtmi.com/caselaws?id=72021 Reassessment under section 148 was considered unsustainable where the revenue had already treated the undisclosed share capital investment as belonging to an identified third person in substantive proceedings. On that footing, a protective reopening of the company's assessment could not be justified merely on suspicion, and the proper course was to use the special machinery for assessing income in the hands of a person other than the searched person. The text also states that share application money cannot be assessed in the company's hands only because the shareholders are alleged to be bogus, where the department has remedies against the shareholders themselves. en-us Fri, 06 Jun 2008 00:00:00 +0530 Sun, 10 Dec 2023 19:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=72021 Reassessment under section 148 was considered unsustainable where the revenue had already treated the undisclosed share capital investment as belonging to an identified third person in substantive proceedings. On that footing, a protective reopening of the company's assessment could not be justified merely on suspicion, and the proper course was to use the special machinery for assessing income in the hands of a person other than the searched person. The text also states that share application money cannot be assessed in the company's hands only because the shareholders are alleged to be bogus, where the department has remedies against the shareholders themselves. Case-Laws Income Tax Fri, 06 Jun 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=72021