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2020 (5) TMI 384 - AT - Income TaxReopening of assessment - client code modification - ingenuine transaction - diversion of income - HELD THAT:- Investigation Directorate, Ahmedabad carried out survey u/s 133(A) to examine the misuse of Client Code Modification for tax evasion. In this case, the client code of the assessee was SS 493 & as per the AO the error by the operator could be in the form of punching Client Code as FS-493, HS-493, SS-439 or similar phonic sounds but certainly Code was S-1. Hence, the modification in this case, was not found genuine by the Assessing Officer as well as CIT (A). Before the AO, the assessee has not at all proved as to why the error has incurred. In the written submissions as well, the assessee submitted that the details of trading and how the loss come across, but the same was not fully satisfied before the AO as well as before the CIT(A) by the assessee. AO has rightly made addition and the same was properly confirmed by the CIT (A). There is no need to interfere with the said finding of the CIT (A). The appeal of the assessee is dismissed.
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