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The Special Leave Petition is dismissed.

Shanti Prime Publication Pvt. Ltd.

Sec. 147 of the Income Tax Act, 1961– Reassessment – Reopening of assessment cannot be based on fishing or rowing inquiries or for carrying out further investigation. Even after non-disclosure, if the documents on record conclusively establish that the receipt did not give rise to any taxable income, it would not be open for the AO to reopen the assessment referring only to the non-disclosure of the receipt in the return of income. Contention of the revenue that the share transaction requires examination which can be done only during the course of reassessment was not sustainable since while determining book profit under section 115JB, AO cannot recomputed the profit in the P &L a/c. SLP of the revenue also dismissed. - ASSTT. CIT V/s SWASTIC SAFE DEPOSIT AND INVESTMENTS LTD. - [2020] 273 TAXMAN 089 (SC)