INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
Yogesh Kumar U.S., J, Shri Brajesh Kumar Singh, ACJ
Aroma Chemicals – Appellant
Versus
ACIT – Respondent
| Table of Content |
|---|
| 1. assessment re-opening based on reversal trades. (Para 1 , 2) |
| 2. arguments against legitimacy of trades. (Para 3 , 6 , 10) |
| 3. judicial evidence required for reopening. (Para 4 , 5 , 12) |
ORDER
PER BRAJESH KUMAR SINGH, AM,
This appeal by the assessee is directed against the order of the National Faceless Appeal Centre (NFAC), Delhi, dated 04.03.2025 [hereinafter referred to as the ‘Ld. CIT(A)’] arising out of the assessment order dated 27.03.2022 passed under Section 147 r.w.s. 144 r.w.s. 144B of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) by the National Faceless Assessment Centre, Delhi, (hereinafter referred to as the ‘Ld. AO’) pertaining to A.Y. 2015-16.
2. In this case, the assessment was reopened vide notice issued u/s 148 of the Act, dated 30.03.2021. The assessment was reopened on the basis of information that the assessee had shown profit of Rs. 1,31,95,650/-, during the financial year 2014-15, relevant to A.Y. 2015-16 through “reversal entries” of option trades, which were carried out with a view to obtain accommodation entries of profit and losses. Several notices, as noted by the AO on page 2 of its order, were issued to the assessee whic
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