2026 (1) TMI 946

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....r dated 16.03.2023 u/s 147 of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') passed by the Assessment Unit, Income Tax Department, Delhi for AY: 2018-19. 2. On hearing both sides we find that the case set up by the assessee before us was primarily on the legal ground No. 4 & 5 which are reproduced below for convenience: "4. On the facts and circumstances of the case, learned CIT(A), NFAC has erred both on the facts and in law in confirming the reassessment order passed by the AO despite the fact that the show-cause notice issued under section 148A(b) of the Act, order passed under section 148A(d), notice issued under section 148 and consequent reassessment order passed under section 147 read with section 144B of....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....e on the basis of alleged information that the assessee has made investment in equity shares at Rs. 86,73,233/-and the copy of this notice is made available at page 5 of the paper book. Then order u/s 148A(d) of the Act was issued on 31.03.2022 and the copy of the order is placed in the paper book from page No.6 to 8 and from the relevant page 7, we find that the allegation is that "the assessee has made expenses through bogus purchases of shares amounting to Rs. 86,73,233/- during the year under consideration." This order mentions of the notice dated 19.03.2022 being issued. 5. Now the case of the assessee is that assessee has not made any investment in equity shares. As we go through the impugned assessment order, we find that in para ....