2018 (12) TMI 1463

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....ce. It is contended that the "reasons to believe", in this case are vague and given that the petitioner had explained in no uncertain terms that the three scrips which were specifically mentioned had in fact not even been transacted for the concerned Assessment Year, the attempt to re-assess the returns yet again, is erroneous. It was further explained by the petitioner's counsel that the respondent/Revenue has not even cared to examine the entire records - had it done so, it would have seen that the scrips were not traded during the year but possibly later. It was therefore, urged that given the materials on record, there was no tangible reason or objective material, supporting a valid reassessment. The Revenue which appears on advance n....

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....heet of beneficiaries and beneficiaries pertaining to their jurisdiction shall pop up. 2. On physical verification as well as from the ITD database it is gathered that the assessee has filed ITR for A.Y.2011-12 on 28.09.201l declaring total income of Rs. 278401/- but not declared any investment or capital gain/loss in his ITR for A.Y.2011-12. No scrutiny assessment has taken place in the case of assessee for the relevant year. 3. In the present case, the undersigned has information as well as reason to believe that the income for A.Y. 2011-12 has escaped assessment as the assessee has not declared any investment or capital gain/loss in his ITR for A.Y.2011-12 with respect to the aforesaid transactions amounting to Rs. 9,62,696.12/-. On be....

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....ances - 1) categorical denial in the reply to the "reasons to believe" with respect to the fact that the transactions of the shares in the three companies had not been undertaken during the concerned Assessment Year and 2) that the Revenue did not look into the records to ascertain whether and if so, the extent of investment that the petitioner had made. The reply of the assessee in this case, we notice - whether it is categorical or otherwise, is unsupported by any document or statement, containing the investments made or copies of the investment account or the shares and securities purchased and traded in. The assessee was afforded an opportunity to provide this but chose not to provide the materials, other than denying the transactions a....