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2018 (5) TMI 1548 - HC - Income TaxReopening of assessment u/s 147 - allotment of shares at premium - assessee had not filed return for the relevant assessment year - allegation that assessee has alloted the share to bogus companies - these were shell companies engaged in providing accommodation entries having dummy directors - Held that:- the reasons recorded by the AO can be challenged on the ground of their validity - thus it is open for the Court to strike down the notice based on such reasons. However, at the stage when the notice for reopening is under challenge, if it is not possible without further detailed inquiry to arrive at a final conclusion, the Court would be well advised in keeping such a question open and permitting further proceedings in connection with the notice of reopening. Petition dismissed - Decided against the assessee.
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