The reasons provided for reopening assessments under Section 147/148 must be specific and cannot be over-broad. Lack of specific details and reasoning in the reassessment notices can lead to their quashing.

S. RAVINDRA BHAT, J.

1. This petition challenges the reassessment notices issued by the Assessing Officer for the A.Y. 2008-09 and 2009-10. The reassessment notice for the A.Y. 2008-09, which outlined the “reasons to believe” in support of the decision to reassess (which was also passed in identical terms for the subsequent year) is extracted below:

“Reasons for reopening the case of M/s Shiv Sai Infrastructure Pvt. Ltd. (PAN-AAJC85095B) For A.Y. 2008-09, u/s 147/148 of the Income Tax Act, 1961.

2. Information/documents alongwith relevant details have been received from the office of Director of Income Tax (Investigation), New Delhi vide their letter F.No.DIT(Inv.)-II/U/s 148/2012-13/196 dated 13.3.2013 and through Addl. CIT, Range-8, New Delhi vide their letter F.No. Addl.CIT/Range-8/2012-13/1020 dated 22.03.2013 that the above assessee, M/s Shiv Sai Infrastructure Pvt. Ltd. has received and is a beneficiary of accommodation entries provided by certain entry operators. The Investigating Wing of the department had carried out search and seizure operations against the various group entry operator which included Surendra Kumar Jain Group to various beneficiary companies alongwith hundreds of bogus companies of the group and many other related entry providers. These search and seizure operations unearthed the modus operandi of these entry operators. The various companies which do not have any business were being used for providing accommodation entries to various assessee who were rerouting their unaccounted cash through these accommodation entries. The assessee would pay cash to the entry providers. This cash would then be deposited in the accounts of various bogus companies and the transactions would be routed through many bank accounts to cover the trail. Then the assessee would be given cheque from one of the many accounts which would be given the colour of share application money or share capital or share premium or loans or advance etc. In the process, the entry operator would earn certain commission. The searches by the Investigating Wing against the entry operators resulted in unearthing of large number of pass books, cheque books, computer hard disks, signed blank cheques, share transfer certificates and many other blank signed documents. This information has been provided by the Investigation Wing of the Income Tax Department to the Assessing Officer.

ii. In the case of the above assessee, the following accommodation entries have been taken:-

S. No.	Beneficiary	PAN	Amount	Total
1	M/s Shiv Sai Infrastructure Pvt. Ltd.	AAJCS5059B	2,00,00,000	2,00,00,000

In view of the above, I am satisfied and I have reason to believe that income of Rs.2,00,00,000/- chargeable to tax has escaped assessment for A.Y. 2008-09, within the meaning of Section 147 of the Income Tax Act, 1961.”

3. The assessee complains that the impugned reassessment notices are unsustainable in law because all the relevant particulars relating to the share application moneys received by it were disclosed to the Assessing Officer. In support, the assessee also urged that the original assessment was done under Section 143(3) of the Income Tax Act, 1961 (hereinafter referred to as “the Act”). During the course of those proceedings, the elaborate questionnaires dated 12.02.2010 and 31.01.2011 were replied to on 26.02.2010, 19.07.2010 and 26.08.2010, 07.09.2010, 09.11.2010, 12.11.2010, 25.11.2010 and 30.11.2010 (for A.Y. 2008-09 and A.Y. 2009-10). It is submitted that the pointed queries with respect to the genuineness, identity and creditworthiness of the share applicants was provided including the bank statements for the relevant years.

4. In respect of the impugned reassessment notice, it is argued that the AO – in the original assessment scrutiny orders did not furnished any reasons why the materials furnished to him, we