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2022 (10) TMI 421

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....under the provisions of the Income Tax Act, 1961 (in short 'Act') for the assessment year A.Y.2011- 2012. The petitioner had filed the return of income, in time, accompanied by the required annexures. The return was taken up for scrutiny and notice under Section 143(2) was issued on 31.07.2012. 3. Inter alia, the assessing authority calls for the attendance of the petitioner to his office to finalise the assessment. Parallelly and separately, a notice had been issued by the Income Tax Officer in the Intelligence and Criminal Investigation wing of the Income Tax Department (ITO(I&CI)), on 05.10.2012. 4. The (ITO(I&CI)) calls upon the petitioner to furnish information under Section 133(6) of the Act including bank statements relatin....

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....true disclosure of relevant facts at the initial stage. 9. The petitioner responded to the notice and sought the reasons for reassessment that read as follows: "3.The assessee is a closely held domestic company, which is engaged in the business of manufacture of gold jewelry. The assessee has filed the return of income for the A.Y. 2011-12 on 30.09.2011 admitting income of Rs.1,46,70,020/- and assessment u/s 143(3) was completed on 28.01.2014 assessing total income at Rs.1,51,11,077/- by disallowing an amount of Rs.4,41,055/- under various heads. 4.The assessee M/s RKR Gold Pvt Ltd maintianed account No.034205500165 with Coimbatore-RS Puram branch which was opened on 27.01.2011 and linked accounts under PAN No AADCR4414M. The account w....

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....ason justifying the reassessment is the failure of the officer to verify the deposits in the ICICI Bank, R.S. Puram Branch at the first instance, and there is no fault has been attributed to the petitioner in that regard. 11. However, this submission is seen to be erroneous in light of the statement of the officer at paragraph 6, wherein he clearly states that the assessing authority had verified the assessment records containing the submissions made by the assessee in response to notices issued during assessment, and has come to the conclusion that the assessee has not fully and truly disclosed the necessary facts. 12. What has transpired is that, post finalisation of the assessment, the Department had received information regarding susp....