TMI Blog2019 (12) TMI 379X X X X Extracts X X X X X X X X Extracts X X X X ..... apital loss in their books of accounts - HELD THAT:- As submitted that the assessment is sought to be reopened on borrowed satisfaction of the investigation wing without making any inquiry into the facts of the case. Assessment is sought to be reopened beyond a period of four years from the end of the relevant assessment year and that in the absence of any failure on the part of the petitioner ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... : HONOURABLE MS.JUSTICE HARSHA DEVANI) 1. Mr. Jaimin R. Dave, learned advocate for the petitioner invited the attention of the court to the reasons recorded for reopening the assessment to point out that the Assessing Officer has recorded that he has received information that M/s. Banas Finance Ltd. is a penny stock listed on BSE with script code and has been used to facilitate introduct ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... called for by the Assessing Officer. 3. It was pointed out that by a communication dated 8th December, 2014 the Assessing Officer called for details of purchase of shares along with date of payment, its mode, copy of certificate issued, broker's bill showing corresponding entries in bank statement etc. as well as details of sale and documentary evidence for the sale receipt received ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... submitted that therefore, the Assessing Officer after due application of mind had consciously allowed the claim of the petitioner and hence, the Assessing Officer now seeks to reopen the assessment on a mere change of opinion. 6. It was further submitted that the assessment is sought to be reopened on borrowed satisfaction of the investigation wing without making any inquiry into the fa ..... X X X X Extracts X X X X X X X X Extracts X X X X
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