https://www.taxtmi.com/caselaws?id=438039 Reopening under ss. 147/148 was challenged on the ground that the Assessing Officer (AO) lacked valid "reasons to believe" where information from the Investigation Wing indicated the assessee's transactions in a penny-stock scrip used to generate bogus exempt long-term capital gains, and the underlying company was prima facie a shell entity. The HC held that at the notice stage, the sufficiency or adequacy of reasons cannot be examined; it is enough that tangible material exists to form a prima facie belief of income escapement. Since the AO relied on specific investigative inputs and recorded belief accordingly, the reopening was upheld and the writ petition was dismissed. en-us Fri, 05 May 2023 00:00:00 +0530 Mon, 12 Jan 2026 10:23:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=438039 Reopening under ss. 147/148 was challenged on the ground that the Assessing Officer (AO) lacked valid "reasons to believe" where information from the Investigation Wing indicated the assessee's transactions in a penny-stock scrip used to generate bogus exempt long-term capital gains, and the underlying company was prima facie a shell entity. The HC held that at the notice stage, the sufficiency or adequacy of reasons cannot be examined; it is enough that tangible material exists to form a prima facie belief of income escapement. Since the AO relied on specific investigative inputs and recorded belief accordingly, the reopening was upheld and the writ petition was dismissed. Case-Laws Income Tax Fri, 05 May 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=438039