2018 (2) TMI 1850

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..... The Revenue is in appeal against the order of Income Tax Appellate Tribunal (ITAT), which upheld the CIT(A)'s direction to delete the amounts brought to tax by the Assessing Officer (AO). The AO for AY 2008-09 re-opened assessment under Section 147 based upon the information received, pursuant to search conducted in the premises of third party. The AO sought to rely upon the reports received fr .....

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..... s, the appellant had discharged its primary onus of establishing the identity of the share holders / applicant ire source of the money. The only reason for revenue to cause further verification was the report relating to survey conducted at the premises of the appellant which forms part of the satisfaction recorded for reopening the assessment proceedings. From the said report it transpires that t .....

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..... is the normal formation of capital in any open economy and the process of capital formation cannot be taken to be representing only unaccounted finds or impeded. All the companies having registered office at that premises undisputedly belonged to Bhushan Group. The sources of capital introduced in these - companies were established during the respective assessment proceedings, including in the cas .....

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