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2018 (8) TMI 205 - DELHI HIGH COURTReopening of assessment - reason to believe - share application moneys were received - Held that:- The material on records show that in all the relevant circumstances in which share application moneys were received by the assessee, the circumstances were explained and all the evidence in support of its contentions was furnished to the AO. In the present case, this Court is of the opinion that apart from that consideration, the reassessment notice is cast in overbroad terms; it merely mentions that pursuant to the search and seizure operations of a third party, some material came to light and that yet other third parties were “Entry Operators”, providing bogus entries in the form of share application credit to the petitioners. The identities of such bogus creditors or Book Entry Operators has not been revealed even though it is known nor are the exact amounts which are reflected in the books of such Entry Operators disclosed as “reasons to believe”. In these circumstances, it is held that the impugned reassessment notices cannot be sustained; they are hereby quashed as are all further consequential proceedings.
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