9911796707
TMI Blog2022 (1) TMI 490X X X X Extracts X X X X X X X X Extracts X X X X ..... ails have been made available before the assessment was completed under section 143(3) of the Act. Just because some information has been received from the Investigation Wing, does not entitle Respondents to reopen assessment based on change of opinion. Merely, deposit of money into the bank account by way of cheque itself is not a ground for escapement of income. Mere high value deposit in the bank account cannot be a reason for reopening under section 148 - The reasons as made available to Petitioner merely indicates information received from Investigation Wing about a particular entity entering into suspicious transaction. That material is not further linked to the conclusion that Petitioner has indulged in any activity which can give ri ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ank account with ICICI Bank, Dombivali Branch. In the said account, there are large valued non-cash transactions between 5th March, 2011 to 12th November, 2011. There was credit transaction of ₹ 744 lacs and debit transaction also of ₹ 744 lacs. In the reasons it is mentioned that the purpose of deployment of such large fund is not known. (b) From the perusal of Form 26AS for A.Y. 2012-2013 Petitioner has received ₹ 1.4 Crores of interest income from M/s. Eske Tex India Private Limited but this has not been disclosed in his return of income. Petitioner is also alleged to have received income of approximately ₹ 12.7 lacs on which TDS is deducted under section 94C by M/s. Sunil Industries. But Petitioner has shown ot ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and ₹ 3,50,40,164/- respectively, has been recorded. It is this amount of investment which was gone to M/s. Eske Tex India Private Limited. Petitioner received interest of ₹ 1,41,18,920/- and has also paid interest of ₹ 1,43,43,518/-. 7. In the reasons for reopening though there is a mention of ₹ 1.4 Crores credit of interest income from M/s. Eske Tex (I) Pvt. Ltd, the reason is silent about the payment of interest of ₹ 1,43,43,518/-. In the computation of income, Petitioner has disclosed interest received of ₹ 1,41,18,920/- and payment of ₹ 1,43,43,518/- restricted to ₹ 1,42,05,185/-. Even in the capital account there is disclosure of interest receipt of ₹ 1,41,18,920/- and interest p ..... X X X X Extracts X X X X X X X X Extracts X X X X
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