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21. Counsel for the Revenue very heavily relied on the decision of the Supreme Court reported in Phool Chand Bajrang Lot's case [1993] 203 ITR 456 and contended that even if the loans taken by the assessee were accepted as genuine in the original assessments and interest paid was allowed as deduction, information obtained during the course of the assessment for the subsequent year will be sufficient for initiating proceedings under Section 147 read with Section 148 of the Act. In other words, it was contended that the decision in Burlop Dealers Ltd.'s case [1971] 79 ITR 609 (SC) has been departed from and the subsequent definite and reliable information showing that the loans were bogus will be sufficient to set in motion, proceedings under Section 147 read with Section 148 of the Income-tax Act. I am of the view that the decision of the Supreme Court in Phool Chand Bajrang Lal's case [1993] 203 ITR 456 is distinguishable. In Phool Chand Bajrang Lal's case [1993] 203 ITR 456 (SC), the assessee-firm claimed that it had borrowed a loan from a Calcutta company: The assessee had produced evidence to show that the loan was raised in cash and interest was paid by cheque or bank draft. A confirmatory letter from the company was also produced. The assessments were completed on that basis. Thereafter, the Income-tax Officer having jurisdiction over the Calcutta company informed the Income-tax Officer of the assessee in a different place that the managing director of the Calcutta company had made a confession to the effect that the company was only a name-lender and had never advanced any loan to any person and this was accepted in the assessments of the (Calcutta) company. On this basis, the Income-tax Officer issued a notice under Section 147(a) of the Act. In the said background, and in considering Burlop Dealers Ltd.'s case [1971] 79 ITR 609 (SC), at page 472, the Supreme Court held thus :