9911796707
TMI Blog2025 (4) TMI 150X X X X Extracts X X X X X X X X Extracts X X X X ..... basis of borrowed satisfaction and without any application of mind by the ld. Assessing Officer. 03. The facts in brief are that the assessee field the return of income on 21.09.2013, declaring total income of Rs. 84,930/-. The assessee was engaged in the business of financing and also deals in shares and securities. The case of the assessee was reopened u/s 147 of the Act, after recording reasons to believe u/s 148(2) and after obtaining approval of the competent authority. Notice u/s 148 of the Act was issued on 19.03.2020. The assessee complied with the said notice by filing the return of income on 04.06.2020, declaring the income of Rs. 84,830/-. Thereafter, the notice u/s 143(2), 142(1) of the Act were issued along with questionnaire ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... certain issues as mentioned below which need further clarification:- Issues as per reasons recorded for reopening On the basis of credible information on record, it is observed that M/s Keynesian Financial Services Pvt. Ltd. has brought back unaccounted fund into its regular books of accounts from bogus shell company without any financial rationale behind such transactions in the financial year 2012-13. Owing the same, I have reason to believe that income chargeable to tax has escaped assessment for the A.Y. 2013-14. 3. In view of the above, you may submit your response with supporting documents (if any) on the above-mentioned issues to undersigned electronically in 'E-proceedings' facility through your account in e-Filling we ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... as not done anything as there was gross non-application of mind by the ld. Assessing Officer. Under these circumstances, we are not in a position to sustain the reopening of assessment. The ld. AR in defense of his arguments relied on the decision of Hon'ble Delhi High court in the CIT vs. Insecticides (India) Ltd. (2013) 38 taxmann.com 403 (Delhi), wherein the Hon'ble High Court has held that the reopening of assessment cannot be allowed on the basis of sanctity, vague reasons, wherein the ld. AO has not mentioned in the reasons recorded the details of transactions and also the details of persons/entity from whom the money was received by the assessee. Considering the facts of the case in the light of the above decision, we are incline ..... X X X X Extracts X X X X X X X X Extracts X X X X
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