2025 (4) TMI 780

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....13. 2. The brief facts relevant for adjudication of the instant case are that the Assessee by filing his return of income for the assessment year under consideration on 30.03.2013, had declared its income of Rs.56,790/-. Subsequently, search action u/s 132 of the Act was conducted on 20.10.2016 on Ranka Group and a warrant was executed in case of the Assessee. Thereafter notice u/s 153 of the Act was issued, in response to which the Assessee filed its return of income on 19.09.2018 declaring the same income of Rs.56,790/- as declared by filing the original return of income. Subsequently the case of the Assessee was reopened u/s 147 of the Act mainly on the ground that as per information, the Assessee is one of the beneficiaries of the bo....

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.... on merits mainly on the reasons "that the Assessee during the course of assessment proceedings duly filed the copies of contract notes, bank statement, details of STT paid and also computation of income. It is not the case of the AO that the broker through whom the Assessee had entered into the transaction of bolt, had ever admitted having indulged in any rigging as alleged. It is also not the case of the AO that the documentary evidence filed before him had any flaws or the AO could point out any fault with the same. Though the AO has held that Shri Naresh Jain had facilitated the Assessee to earn the bogus gain, however, the AO has not brought on record any material which showed that Shri Naresh Jain had either paid the money to the Asse....