TaxTMI 
TaxTMI 
2023 (7) TMI 1163
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....Petition, two very old, loyal and trusted employees wanted to start an independent diamond trading business. Two of the directors of Petitioner decided to assist them and help them in setting up business namely M/s. Jogi Gems. M/s. Jogi Gems was a partnership firm in which two of the directors of Petitioner were partners. They added the two loyal employees as partners in M/s. Jogi Gems and after that they retired from the said firm M/s. Jogi Gems. 3. For the year ended March 31, 2019, i.e., Assessment Year (AY) 2019-20, Petitioner filed return of income on 10th October 2019 declaring a total income of Rs. 15,90,17,635/-. On 18th February 2020 Petitioner filed a revised return of income declaring a total income of Rs. 16,51,00,574/-. The As....
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....etitioner. If it was made available, we do not see why Petitioner would state that it was never received by him. At the same time there is nothing to indicate that this information was provided and certainly the details/documents of the investigation of M/s. Jogi Gems has not been made available to Petitioner. Moreover, it is stated in the impugned order that Petitioner has undertaken accommodation entries in the form of imports from M/s. Jogi Gems. On what basis such a conclusion has been arrived at is not stated in the impugned order. Even assuming Petitioner was using its group companies to import diamonds to escape any regulation by Government Authorities and Banks with respect to the related party transactions, we do not understand how....