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ITAT upheld deletion of additions made regarding alleged bogus commodity trading transactions through Client Code Modification. The Special Fraud Investigation Office and DDIT Investigation reports, which formed the basis for reopening assessment under Section 147 for AY 2012-13 to 2014-15, failed to establish any wrongdoing by appellant in client code modifications or other activities. Appellant successfully demonstrated use of own funds for National Spot Exchange Limited platform transactions, with profits already declared for taxation. Tribunal found First Appellate Authority's deletion of additions justified as allegations lacked substantive evidence of illegal trading or tax evasion. Addition deleted and appeal dismissed.
ITAT upheld deletion of additions made regarding alleged bogus commodity trading transactions through Client Code Modification. The Special Fraud Investigation Office and DDIT Investigation reports, which formed the basis for reopening assessment under Section 147 for AY 2012-13 to 2014-15, failed to establish any wrongdoing by appellant in client code modifications or other activities. Appellant successfully demonstrated use of own funds for National Spot Exchange Limited platform transactions, with profits already declared for taxation. Tribunal found First Appellate Authority's deletion of additions justified as allegations lacked substantive evidence of illegal trading or tax evasion. Addition deleted and appeal dismissed.
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