9911796707
TMI Blog2019 (8) TMI 1892X X X X Extracts X X X X X X X X Extracts X X X X ..... n stocks and securities, with trading members - AO citing a SEBI circular of 29.07.2011, and after examining several instances held that the shifting was contrary to the guidelines inasmuch as there was no similarity, in the nature of transactions or the parties, involved with client code - assessee s appeal was allowed on both the questions of reopening of assessment as well as on the merits - I ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , the findings of the CIT (A) have been confirmed by the ITAT; consequently, the Court is now called upon to examine and appreciate concurrent factual findings. No substantial question of law arises. - Hon'ble The Chief Justice S. Ravindra Bhat And Hon'ble Mr. Justice Inderjeet Singh For the Appellant : Mr. Siddharth Bapna on behalf of Mr. Anil Mehta, AAG. For the Respondent ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , the ITAT concurred with the findings of the CIT(A). The ITAT took into account the submissions of revenue, specially the effect of the circular dated 29.07.2011. It was also significantly observed that neither was survey conducted under section 133(6) by the AO despite the specific request of the assessee nor was any notice under section 131 issued in respect of transactions which led to the shi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... have involved in such mischievous practice but to make such addition in the hands of the assessee it is necessary to establish that the assessee and the other parties alongwith brokers are in collusion. Further there should also be exchange of money between the parties as a consideration for such a transfer of profit. Even otherwise when it is not found that originally these trades were carried o ..... X X X X Extracts X X X X X X X X Extracts X X X X
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