2025 (7) TMI 322

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....x Act, 1961 [the Act] as well as consequent notice issued under Section 148 of the Act. 2. The petitioner had filed its income tax return on 18.10.2017 declaring an income of Rs. 61,35,36,200/- for Assessment Year [AY] 2017-18. Thereafter on 26.03.2019, the petitioner filed a revised income tax return declaring an income of Rs. 61,10,86,200/- for AY 2017-18. The return was picked up for scrutiny and the Assessing Officer [AO] completed the assessment for AY 2017-18 and passed an order dated 22.11.2019 under Section 143(3) of the Act. 3. The AO initiated proceedings for reopening of the assessment by issuing a notice under Section 148A(b) of the Act on 26.03.2024. According to the AO, the information as set out in the Annexure to the s....

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....mittances has been analyzed and during the analysis of remittances data/information it was observed that the amount reflected in the remittance data obtained from the bank does not tally with the amounts reflected in the bank statement of the assessee. Assessee company has made total foreign remittances amounting to Rs. 6,50,84,454/- during the AY 2017-18. Copies of all the relevant documents are attached herewith this notice. 2. Therefore, an amount of Rs. 6,50,84,454/- appears to have escaped assessment for the A.Y. 2017-18 which needs to be brought to tax by issuing notice u/s 148 of the Income Tax Act, 1961. Accordingly, you are hereby required to show cause as to why proceedings u/s 148/148A of the Act should not be i....

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....the impugned order is set out below: "e) On further perusal of the information/details available on Insight Portal, it is revealed that the assessee has entered into the following foreign remittances transactions during the assessment year under consideration: S.No. Information type Amount (Rs.) 1 Sending of foreign remittance as per Form-15CC 1,28,84,470/- 2 Receipt of remittance by a non-resident or by a foreign company as per Form-15CA 7,08,50,894/- 3 Certificate of accountant on foreign remittance as per Form-15CB 3,00,31,665/-   Total 11,37,67,029/- It is evident from the above information that assessee has entered into inward and outward foreign remittances which was ....