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TMI Blog2019 (2) TMI 720X X X X Extracts X X X X X X X X Extracts X X X X ..... ge in circular trading to enable the generation of either profits or losses as required by clients at the end of the financial year - Held that:- Tribunal accepted the assessee's explanation and discarded the Revenue's theory that profit of the assessee's company were passed on to the clients. It was also noticed that the Revenue has not contended that the client code modification facility is ofte ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , which is wholly impermissible. - Decided against revenue. - Income Tax Appeal No.1257 of 2016 With Income Tax Appeal No. 1383 of 2016 - - - Dated:- 15-1-2019 - Akil Kureshi And M.S. Sanklecha, JJ. For the Appellant : Mr. Arvind Pinto For the Respondent : Mr. Sanjiv M. Shah ORDER P.C. 1. These appeals involve the same assessee and arise out of common background. We may ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on was to indulge in circular trading to enable the generation of either profits or losses as required by clients at the end of the financial year? 3. The respondent assessee is a private limited company engaged in the business of providing commodity services to its clients. In the return of income filed by the assessee for the Assessment Year 200607, the Assessing Officer noticed that there ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he investors, who may have sizable profit arising out of commodity trading against which such losses can be set off. The Revenue normally points out number of such instances of client code modifications as well as nature of errors in filling of the client code. At any rate, what can be taxed in the hands of the present assessee is the income escaping assessment. Even if the Revenue's theory of ..... X X X X Extracts X X X X X X X X Extracts X X X X
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