https://www.taxtmi.com/caselaws?id=465628 Reopening under s.147 was sustained because specific investigation inputs on large-scale penny-stock price rigging and operator statements constituted tangible material sufficient to form a bona fide "reason to believe" that income had escaped assessment; prior to insertion of s.148A, the AO was not required or empowered to conduct pre-notice enquiry, and the assessee's objection of no assessee-specific material was rejected, resulting in the reassessment notice being upheld. Additions under ss.68 and 69C were affirmed as the assessee failed to establish the genuineness and commercial rationale of an off-market preferential allotment, could not explain the abnormal price rise unsupported by fundamentals, and purchasers were untraceable under s.133(6), corroborating accommodation-entry findings; the appeal was dismissed. en-us Mon, 26 Feb 2024 00:00:00 +0530 Fri, 02 Jan 2026 12:25:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465628 Reopening under s.147 was sustained because specific investigation inputs on large-scale penny-stock price rigging and operator statements constituted tangible material sufficient to form a bona fide "reason to believe" that income had escaped assessment; prior to insertion of s.148A, the AO was not required or empowered to conduct pre-notice enquiry, and the assessee's objection of no assessee-specific material was rejected, resulting in the reassessment notice being upheld. Additions under ss.68 and 69C were affirmed as the assessee failed to establish the genuineness and commercial rationale of an off-market preferential allotment, could not explain the abnormal price rise unsupported by fundamentals, and purchasers were untraceable under s.133(6), corroborating accommodation-entry findings; the appeal was dismissed. Case-Laws Income Tax Mon, 26 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465628