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TMI Blog2022 (10) TMI 895X X X X Extracts X X X X X X X X Extracts X X X X ..... 2 passed by the learned CIT(A), National Faceless Appeal Centre, Delhi and it relates to A.Y. 2013-14. The assessee, inter alia, has challenged the validity of reopening of assessment under section 147 of the I.T. Act. 2. The learned AR submitted that the assessee had filed the return of income for the year under consideration on 9.12.2014 declaring income of Rs.10,39,050/-. Subsequently the Asse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... uld lead the Assessing Officer to arrive at the belief that the income of A.Y. 2013-14 has escaped assessment. Accordingly, the learned AR submitted that there was no live nexus between the information received and the belief formed by the Assessing Officer. Accordingly he submitted that the reopening of assessment is bad in law. 3. The learned DR submitted that the assessee has challenged the va ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s long term capital gain entries in the scrip of M/s Sampada Chemicals Ltd during the financial year 2010-11. M/s Sampada Chemicals Ltd was a bogus entity managed, controlled and operated by Shir Vipul Vidur Bhatt for providing bogus long term capital gain accommodation entries to the various entities for commission. The DDIT(lav) Unit 7(4) Mumbai also communicated that on perusal of the return of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... material relied upon by the Assessing Officer should have a live or proximate link with escapement of income. It was so held by Hon'ble Delhi High Court in the case of Amsa India Pvt. Ltd. Vs. CIT (WTC 5143/2005) and also in the case of Moser Bare India Ltd. Vs. DCIT (WPC 7677/2011 dated 6.1.2012). In the fact and circumstances of the case, I find that there was material in the hands of the A ..... X X X X Extracts X X X X X X X X Extracts X X X X
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