9911796707
TMI Blog2023 (9) TMI 1319X X X X Extracts X X X X X X X X Extracts X X X X ..... h of Standard Chartered Bank. The details of the savings bank account were also provided in the reply dated 03.03.2023. The first part of this paragraph does not align with the second part, however what does come through if both parts are read together is the petitioner had, in fact, deposited Rs. 40,00,000/- with BKR and not received the said amount by way of loan as alleged. AO though, was not persuaded, and went on to conclude in the order dated 26.03.2023, passed u/s 148A(d) of the Act that income amounting to Rs. 40,00,000/- had escaped assessment without providing the necessary basis in support of the application. Best way forward would be to dispose of the writ petition with the following directions: (i) Since the principal ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 5. Via the instant writ petition, the challenge is laid to the following notices and order: (i) Notice dated 23.02.2022, issued under Section 148A(b) of the Income Tax Act, 1961 [in short, the Act ]. (ii) Order dated 26.03.2023, passed under Section 148A (d) of the Act. (iii) Consequential notice of even date i.e., 26.03.2023, issued under Section 148 of the Act. 6. The principal allegation which is levelled against the petitioner is that he is a beneficiary of an accommodation entry provided by one Mr Bajrang Lal Periwal, via a company going by the name BKR Capital Pvt. Ltd. [hereafter referred to as, BKR ]. 7. It is alleged that the petitioner has taken a fictitious loan amounting to Rs. 40,00,000/- from BKR. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ws: The said deposit was advanced by the assessee from his savings bank account No. 52610011762 held with Standard Chartered Bank, Defence Colony, New Delhi. 10.2 The first part of this paragraph does not align with the second part, however what does come through if both parts are read together is the petitioner had, in fact, deposited Rs. 40,00,000/- with BKR and not received the said amount by way of loan as alleged. 11. The Assessing Officer (AO), though, was not persuaded, and went on to conclude in the order dated 26.03.2023, passed under Section 148A(d) of the Act that income amounting to Rs. 40,00,000/- had escaped assessment without providing the necessary basis in support of the application. 12. In our view, the be ..... X X X X Extracts X X X X X X X X Extracts X X X X
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