9911796707
TMI Blog2019 (10) TMI 553X X X X Extracts X X X X X X X X Extracts X X X X ..... count of trading in shares of M/s. Banas Finance Ltd. - HELD THAT:- Prima facie, the impugned notice seems to be founded on change of opinion and, therefore, without jurisdiction. Besides, as the impugned notice has been issued beyond a period of four years from the end of the relevant Assessment Year, the requirement of the Petitioner having failed to disclose all material facts truly and fully, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... h March, 2019 issued under Section 148 of the Income Tax Act, 1961 (the Act). The impugned notice dated 28th March, 2019 seeks to re-open the Assessment for Assessment Year 2012- 13. The reasons in support of the impugned notice proceed on the basis that the Petitioner had dealt in the shares of a Penny Stock Company viz. M/s. Banas Finance Company Ltd., on the Bombay Stock Exchange. Ther ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to the stock exchange and concerned paries. On being satisfied that the transactions were genuine, the Assessing Officer in his order under Section 143(3) of the Act allowed the claim of the Petitioner even in respect of the earnings made on account of trading in shares of M/s. Banas Finance Ltd., Thus, prima facie, the impugned notice seems to be founded on change of opinion and, therefore, witho ..... X X X X Extracts X X X X X X X X Extracts X X X X
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