High Court rules no income escape warranting reassessment as no share sale occurred. Petitioner's evidence supports no income.

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....The High Court considered the issue of reopening assessment u/s 148A based on a difference between allotment price and market price of shares. It was held that as no sale of shares occurred in the relevant year, there was no income escape warranting reassessment. The court found the basis for the reassessment order to be lacking as no other grounds were provided. The Writ Petition was allowed as there was a failure to apply mind to the facts and the petitioner's evidence showing no income from share sales. The court rejected the Revenue's request for remand, stating it lacked merit.....