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2024 Supreme(Bom) 257

K. R. SHRIRAM, NEELA GOKHALE
Chandni J. Ahuja – Appellant
Versus
Union of India, through the Secretary, Government of India, Ministry of Finance – Respondent


Advocates Appeared:
For the Petitioner:Ms. Chandni J. Ahuja, (Petitioner Present In Person.)
For the Respondents: Mr. Prakash Chhotaray.

JUDGMENT :

(K.R. Shriram, J.) :

1. Petitioner, a Chartered Accountant by profession, had filed return of income for Assessment Years 2010-2011, 2011-2012 and 2012- 2013. The return for all the three years were processed under Section 143(1) of the Income Tax Act, 1961 (the Act). Thereafter, petitioner received identically worded notices all dated 20th March 2015 for Assessment Years 2010-2011, 2011-2012 and 2012-2013 seeking to reopen the assessment of those years. The reasons in support of the impugned notices are also identical, except the years and figures vary. The reasons read as under :

    In this case as per the CIB information you have entered into huge share transaction for A.Y. 2010-11. As per the information received the value of the share transaction is Rs.29,43,22,193/-.

In view of the above, I have reason to believe that income chargeable to tax has escaped assessment and, therefore, to verify the above aspect, it is necessary to reopen the case for A.Y. 2010-11.

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In this case as per the CIB information you have entered into huge share transaction for A.Y. 2011-12. As per the information received the value of the share transaction is Rs.18,11,26,743/-.

In view of t

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