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2022 (12) TMI 1006 - AT - Income TaxReopening of assessment u/s 147 - addition in respect of shifting of profit - HELD THAT:- As client code has been changed with a few clients which pertain to groups which are apparently related to each other and in one case related to the appellant also cannot be a mere coincidence. Such transactions cannot be held to be genuine as they fail the test of human probabilities. The above finding of the learned CIT(Appeals) is not rebutted by the assessee by placing any contrary material on record. Therefore, see no reason to interfere in the order of the learned CIT(Appeals) and the same is affirmed. - Decided against assessee.
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