2024 (7) TMI 951

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....ugule ORDER PER AMIT SHUKLA (J.M): The aforesaid appeal has been filed by the assessee against order dated 12/02/2024 passed by NFAC, Delhi for the quantum of assessment passed u/s. 147 for the A.Y. 2013-14. 2. None appeared on behalf of the assessee. Accordingly, appeal is being decided on the basis of material on record and the orders of the authorities below. 3. The ld. CIT(A) ha....

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....g Mill Pvt. Ltd. From the information in the public domain, it was found that these entities were not filer and therefore, purchases made from two parties is unexplained. Sr. No. Name of the Party Amount paid (in Rs. ) FY in which payment made 1 Mukesh Steel Corporation 2,55,73,016 2012-13 2 Shah Steel Corporation 10,50,412 2012-13   Total   ....

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....he trading amount. Nowhere, it has been brought on record that when this information came to the notice of the ld. AO, if the transaction relates to F.Y.2012-13 and reopening has been done almost after nine years from the end of the relevant assessment year. Now, the case is reopened u/s. 147 by issuance of notice u/s. 148 on 30/01/2021 to reopen the case for the A.Y. 2013-14. The time limit for r....

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....ale of purchases have been accepted alongwith gross profit in the original assessment order u/s. 143(3) dated 20/03/2016. Thus, even under the terms of first proviso to Section 147 as was then applicable, no reopening can be done after expiry of four years from the end of the relevant assessment year unless any income chargeable to tax has escaped assessment for the reasons of the failure on the p....