TaxTMI 
TaxTMI 
2025 (6) TMI 566
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....laring total loss of Rs. 64,512/-. Information was received from Investigation Wing that the assessee is one of the beneficiaries, who has availed benefit from shell companies floated of Banka Group. Accordingly notice under section 148 of the Act was issued on 31.03.2021. The assessee filed return of income in response to notice under section 148 on 30.04.2021 declaring loss of Rs. 64,512/-. Thereafter the ld. Assessing Officer issued notice under section 143(2) of the Act to the assessee and the same was served on the assessee. In response to the notice issued under section 143(2), the assessee had filed objections but the ld. Assessing Officer did not consider the objections raised by the assessee saying that the objections are not maint....
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....e sides. It was the submission of the ld. Departmental Representative that the ld. Assessing Officer received credible information from the Investigation Wing that the assessee is one of the beneficiaries, who has availed benefit from the shell companies floated of Banka Group. He further argued that the ld. Assessing Officer has gone through the balance-sheet of the assessee-company, which clearly shows that the assessee is in receipt of Rs. 20,00,112/- in the form of loan from the abovementioned shell companies of Banka Group. The assessee was asked to explain the nature of these transactions. The assessee has replied that the assessee-company has not dealt with Banka Group. After examining all the facts, the ld. Assessing Officer came to....
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....further submitted that the assessee has established all the details before the ld. CIT(Appeals), the ld. CIT(Appeals) after examining all details filed by the assessee, allowed the appeal of the assessee saying that there was no transaction between the assessee-company and Banka Group. Therefore, ld. Counsel for the assessee pleaded to uphold the order passed by the ld. CIT(Appeals). 7. I have perused the material available on record and the orders passed by the lower authorities. It is an admitted fact that after receipt of notice under section 148 of the Act, the assessee requested the ld. Assessing Officer to furnish the date of alleged transaction and also informed the ld. Assessing Officer that he has not received any loan amount of R....