Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2021 (12) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2021 (12) TMI 920 - ITAT DELHIReopening of assessment u/s 147 - assessee has made transactions in commodities exchange during the impugned assessment year and had not filed its return of income - assessee neither responded to the notice issued under section 148 nor responded to the notice issued under section 142(1) therefore, the A.O. estimated the profit @ 0.5% and added an amount to the total income of the assessee under section 69 - As submission of Assessee that no reasonable opportunity was given to the assessee to explain the source of margin money and notice was never served on the assessee from the side of the A.O. for which there was no compliance and the A.O. had passed the order under section 144- HELD THAT:- In the totality of the facts and circumstances of the case and in the interest of justice, we deem it proper to restore the issue to the file of A.O. with a direction to give one more opportunity to the assessee to substantiate its case and decide the issue as per fact and Law. The assessee is also hereby directed to appear before the A.O. and substantiate its case without seeking any adjournment under any pretext, failing which, the A.O. is at liberty to pass appropriate order as per Law. The grounds raised by the assessee are accordingly allowed for statistical purposes.
|