2023 (7) TMI 512

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.... on 5th October 2016 return for Assessment Year 2016-17 declaring a total amount of Rs. 96,590/- as income. 3. Petitioner then received a notice dated 24th August 2018 under Section 142(1) of the Income Tax Act, 1961 (the Act) calling upon petitioner to furnish various information as per annexture to the said notice. One such information, i.e., relevant to the matter at hand is "Please submit details of all the properties purchased during the year along with copies of purchase deeds and copy of the statement of bank account from which the payment was made". Petitioner replied to this notice by its letter dated 7th September 2018 and gave following details : 5. Copy or Purchase deed for properties purchased during the year. Durin....

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....here was information which suggests that income chargeable to tax for Assessment Year 2016-17 has escaped assessment. The details of the information/enquiry conducted on which reliance was placed alongwith supporting documents are also mentioned in the annexture to the notice. Petitioner was called upon to show cause as to why a notice under Section 148 of the Act should not be issued. Due to information uploaded in VRU Model under Insight portal, the case of petitioner was picked up in High Risk CRIU/VRU from Insight portal as petitioner has entered into transaction of purchase of immovable property amounting to Rs. 28,50,00,000/- relates to Assessment Year 2016-17. In the information description the same property is mentioned twice and Mr....

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....ioner has not furnished relevant bank statement evidencing the payments made for purchase of the property during the year and has also not explained the source during the course of issuance of notice under Section 148A(b) of the Act. 7. In our view, all these findings are incorrect in as much as in the notice under Section 142 (1) issued on 24th August 2018, petitioner was expressly called upon to submit all the details of all the properties purchased alongwith copies of purchase deed and copy of statement of the bank account from which the payment was made. In its reply dated 7th September 2018 petitioner has given details of property purchased including copies of Purchase Deed. The Purchase Deed also contains details of payments made. ....