Reopening under section 147 on mechanical basis void even where s. 143(3) assessment not made

The assessee- company allotted shares to four companies. The allottee companies were active as per the records of the ROC and were allotted PAN and assessed to income-tax. Though the assessee filed a return, no assessment u/s 143(3) was made. The AO subsequently received information from the ADIT (Inv) unit that the assessee had received “bogus accommodation entries” in the form of share application money from the said four companies. The AO accordingly issued a notice u/s 148 seeking to reopen the assessment. The assessee challenged the reopening on the ground that (i) the reasons did not...