2026 (2) TMI 933

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....he Ld. CIT(A)]. 2. At the outset, we observe from the appeal folder that the appeal of the assessee is barred by limitation by 142 days for which the condonation petition was filed. After going through the contents of the application, we find that the delay is attributable to bonafide and genuine reasons and therefore, we are inclined to condone the delay and admit the appeal for adjudication. 3. The issue raised in Ground No. 1 is against the order of Ld. CIT(A) confirming reopening of assessment which was made on the basis of borrowed satisfaction without application of mind and without making any enquiry into information received from the AO and thus there was no tangible material to reopen the case. 4. The facts in brief are th....

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....sessee showed only Rs. 5.00 lacs as long term capital gain and as such the capital gain of Rs. 2,61,50,000/- on sale of shares of two companies appears to have escaped assessment. We note that the AO has simply relied on the information received from the Directorate of Investigation, Forensic Division Competent Authority Singapore, without any verification on its own as apparent from the facts mentioned by the AO in the reasons recorded. We noted that during the year assessee has sold Rs. 6,11,500 equity shares for Rs. 3,22,65,000/-. We note that the assessee had purchases 10,000 equity shares at total cost of Rs. 1,00,00,000/- in the earlier assessment years which was brought forward. Thereafter, the assessee purchased remaining shares of ....