Bogus share capital: Reassessment on mere investigation wing report is invalid

M/s Balaji Health Care Pvt. Ltd. Vs ITO (ITAT Jaipur)

Conclusion: Reopening of assessment by AO on basis of report of Investigation Wing that assessee was beneficiary  of accommodation entries in the form of share capital/premium/loan during the financial year was not justified as AO had not carried out any further examination and analysis in order to establish the nexus between the material and formation of belief that income had escaped assessment and there was no linkage which could be said to have been established by AO between assessee’s undisclosed income which was routed

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