JUDGMENT

Akil Kureshi, J. - At the request of the parties, the petition is taken up for final disposal at the stage of admission.

2. This petition under Article 226 of the Constitution of India challenges notice dated 30th March, 2018 issued by the respondent No.1 Assessing Officer under Section 148 of the Income Tax Act, 1961 ("the Act" for short). The impugned notice seeks to reopen the assessment for Assessment Year 201112.

3. The undisputed facts are that the regular assessment proceedings were completed on 21st March, 2014 under Section 143(3) of the Act. Thereafter, the Assessing Officer has issued the impugned notice seeking to reopen the assessment for the assessment year 201112.

4. The reasons in support of the impugned notice as communicated to the petitioner read as under:

"01. The assessee filed its return of income declaring income of Rs. 1,56,64,480/on 28/09/2011. The assessee company is engaged in the business of selling of four wheeler and provide sales services. The assessment was completed under section 143(3) of the Income Tax Act, 1961 on 23.03.2014 and income assessed of Rs. 1,75,61,370/.

02. In the instant case, the information received from Assistant Director of Income tax (Inv), unit 6(3), New Delhi which are as follows: This unit had conducted search in case of Himanshu Verma Group on 29.03.2012. This group was centralised with the Assessing Officer of Central Circle 20, Delhi (ACIT, Central Circle 20, Delhi.)

2. Shri Himanshu Verma was engaged in the activities of providing accommodation entries to various beneficiaries group. He did this by incorporation of numerous corporate and non-corporate entities where directors/partners/proprietors were his employees and closed associates.

3. Modus operandi of Sh. Himanshu Verma was observed to be mainly of three types:

i) He used to take cash from the beneficiaries, deposit the same in some of his entities/individuals'' bank accounts, routing the same and finally remitting it to various companies of the beneficiary group in the form of share application money, share capital and/or unsecured loan.

ii) He used to accept cheques of one set of companies of beneficiary group to the bank accounts of some his corporate entities, rotate the same through his various group entities, finally remitting the same to some other set of beneficiary companies. Through this method, the beneficiary group companies used to inflate their balance sheets for the purpose of procuring more funds from banks/financial institutions. This method was also applied for siphoning off fund from public limited company to the Pvt. Limited companies of the same group.

iii) He used to take cheques of the beneficiary companies and used to issue them sale bills, mainly of fabrics and related articles. This cheque amount was either withdrawn immediately or after rotating the same amongst its group entities. The cash was then returned back to the beneficiary companies. This method was adopted by some concerns who wanted to inflate their purchases.

4. M/s MY CAR PUNE PRIVATE LIMITED, the assessee has taken accommodation entry from Himanshu Verma Group in F.Y. 201011 as follows: