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2021 (9) TMI 1006 - HC - Income TaxReopening of assessment u/s 147 - Satisfaction recorded by AO - HELD THAT:- CBI, Mumbai has filed FIR against the directors of the assessee company and M/s Ardor International Private Limited in which it was stated that modus operandi was a circular routing of funds among inter related parties having common management and address. This information also emphasized that the income chargeable to tax has escaped assessment. The AO with independent application of mind has reopened and the instant proceeding under Section 147 have been initiated after deriving at a satisfaction by the AO. He has also recorded the reasons in writing with independent application of mind. He is expected to form only a prima facie opinion or belief and therefore, according to the respondent, presently no interference is desirable. The rejoinder affidavit is also filed denying all these aspects and also calling various decisions. The Court has heard extensively both the sides and also examined the material on record. It also called for the details of the FIR filed by the CBI. Since the Court was disinclined to entertain this petition, learned advocate Mr. Mehta has, on instruction, chosen to withdraw this petition.
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