2019 (2) TMI 720

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....espondent : Mr. Sanjiv M. Shah ORDER P.C. 1. These appeals involve the same assessee and arise out of common background. We may note the facts from Income Tax Appeal No.1257 of 2016. This appeal is filed to challenge the judgment of the Income Tax Appellate Tribunal ("the Tribunal" for short). 2. Following questions are raised for our consideration : (i) Whether in law and on ....

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....rvices to its clients. In the return of income filed by the assessee for the Assessment Year 200607, the Assessing Officer noticed that there were instances of client code modifications. The Assessing Officer believed that the same was done to indulge in circular trading to pass on profits or losses to the clients of the assessee company as per requirements. After hearing the assessee, the Assessi....

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....de. At any rate, what can be taxed in the hands of the present assessee is the income escaping assessment. Even if the Revenue's theory of the assessee having enabled the clients to claim contrived losses, the Revenue had to bring on record some evidence of the income earned by the assessee in the process, be it in the nature of commission or otherwise. In the present case, the Assessing Offic....