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2024 (10) TMI 1649

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....d. 'CIT(A)'] dated 27.05.2024 arising out of the assessment order framed u/s 147/144/144B of the Act dated 31.03.2022. 1.1. The brief facts of the case of the appellant are that the assessee Nabiul Industrial Metal Pvt. Ltd. did not file the return of income for the AY 2017-18 as a result of which case of the assessee was re-opened u/s 147 of the Act. The Assessing Officer (hereinafter referred to as ld. 'AO') received information from the investigation wing, Kolkata wherein it was mentioned that in course of the investigation in the case of M/s. Darsh Coke Trading Pvt. Ltd., it was revealed that the said company is a paper company through which entry operators provide bogus entries and layer money in exchange of commission. I....

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....cation about the applicability of the faceless scheme for making assessment in faceless manner prior to 29.03.2022." 1.3. Ld. Counsel for the assessee submitted that the provisions of Section 151A of the Act came in the statute on 01.11.2021 but it was notified with effect from 29.03.2022. But in the present case, assessment proceedings to the NFAC started on 29.11.2021 which is evident from the notice u/s 142(1) of the Act. Ld. Counsel for the assessee further submits that the show cause notice has also been issued and the date has been mentioned as 28.03.2022 that is prior to 29.03.2022. Ld. Counsel for the assessee further submits that the assumption of jurisdiction by the NFAC was without jurisdiction. Consequently, the whole assessm....

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....961); (b) "automated allocation" means an algorithm for randomised allocation of cases, by using suitable technological tools, including artificial intelligence and machine learning, with a view to optimise the use of resources. (2) Words and expressions used herein and not defined, but defined in the Act, shall have the meaning respectively assigned to them in the Act. 3. Scope of the Scheme.-For the purpose of this Scheme,- (a) assessment, reassessment or re-computation under section 147 of the Act, (b) issuance of notice under section 148 of the Act, shall be through automated allocation, in accordance with risk management strategy formulated by the Board as referred to in section 148....

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....t Centre Delhi Faceless Assessment: India To, NABIUL INDUSTRIAL METAL PRIVATE LIMITED VILL AND POST DHADIMBA, DIST PASCHIM MEDINIPUR MIDNAPORE 721301, West Bengal India PAN: Assessment Year: Date: DIN: AAECN3170B 2017-18 29/11/2021 ITBA/AST/F/142(1)/2021- 22/1037352059(1) ITBA/AST/F/142(1)/2021- 22/1037352059(1) Notice under sub-section (1) of Section 142 of the Income Tax Act, 1961 Dear Taxpayer, Kindly refer to ongoing assessment proceedings in your case for A.Y. 2017-18 under Faceless Assessment Scheme, 2019. 2. We appreciate the anxiety and uncertainty that is facing all of us in the times of Covid-19. This communication is to assist you in ending one uncertainty, which is pending e-Assessment in your case....

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....n your case .- This order is passed under section 144 rws 147 rws 144B The assessee had not filed its return of income for the A.Y.2017-18. Subsequently. t he case of the assessee was reopened u/s. 147 of the I.T Act after recording the following reason for reopening the case: Reasons for re-opening of the assessment in case of Nabiul Industrial Metal Pvt Ltd for assessment year 2017-18 u/s.147 of the I. T. Act, 1961. 1. Brief details of the assessee : As per e-filing records, the assessee company has not filed its return of income for the relevant assessment year. 1. Breif details of information collected/received by the AO : Information has been received from The DDIT (Inv), Unit-4(2), Kolkata, stating that during the....