Sec. 147 & 148 of Income Tax Act, 1961—Reassessment—The reopening of assessment which was framed after the scrutiny would not be permissible for a fishing or roving inquiry as there is no basis to proceed on the premise that the allocation of shares was at an artificially high premium, merely because a sizeable sum was received in the nature of share premium during the year under consideration, would not automatically mean that the same was artificially increased and the duty on the part of the assessee to explain the nature of credits and genuineness and justification of the share premium would arise when called upon during the assessment or validly reopened assessment — HITACHI HI REL POWER ELECTRONICS P. LTD. Vs. ASSTT. CIT  [2020] 421 ITR 574 (GUJ)