2025 (4) TMI 150

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....ing of assessment u/s 147 of the Act, on the basis of borrowed satisfaction and without any application of mind by the ld. Assessing Officer. 03. The facts in brief are that the assessee field the return of income on 21.09.2013, declaring total income of Rs. 84,930/-. The assessee was engaged in the business of financing and also deals in shares and securities. The case of the assessee was reopened u/s 147 of the Act, after recording reasons to believe u/s 148(2) and after obtaining approval of the competent authority. Notice u/s 148 of the Act was issued on 19.03.2020. The assessee complied with the said notice by filing the return of income on 04.06.2020, declaring the income of Rs. 84,830/-. Thereafter, the notice u/s 143(2), 142(1) o....

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....ging the care and diligence you have taken in preparing the return, there are certain issues as mentioned below which need further clarification:- Issues as per reasons recorded for reopening On the basis of credible information on record, it is observed that M/s Keynesian Financial Services Pvt. Ltd. has brought back unaccounted fund into its regular books of accounts from bogus shell company without any financial rationale behind such transactions in the financial year 2012-13. Owing the same, I have reason to believe that income chargeable to tax has escaped assessment for the A.Y. 2013-14. 3. In view of the above, you may submit your response with supporting documents (if any) on the above-mentioned issues to ....