Reassessment valid under s.148/s.148A(1)/s.143A(3)/s.148(3)(i); CBDT risk data sufficed, liquidation not proof of sham transactions or bogus concern

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....The HC allowed the writ petition, holding that the AO possessed sufficient material to initiate reassessment proceedings under s.148 read with s.148A(1) and to frame an order under s.143A(3); the impugned action was taken pursuant to information generated under the CBDT's Risk Management Strategy recognised by s.148(3)(i). The court rejected the AO's inference that liquidation of a counterparty (hereinafter "Entity X") amounted to proof of a bogus concern, noting that subsequent acquisition of Entity X evidenced commercial legitimacy and that liquidation alone cannot justify a presumption of sham transactions. It was also noted that no complaint of denial of hearing under s.148A(1) was made.....