TMI Blog2022 (9) TMI 930X X X X Extracts X X X X X X X X Extracts X X X X ..... verify the trade in Crypto currency rather, the assessee ought to have submitted before the authority the relevant ledger statement evidencing that he had entered into trade of Crypto currency in the manner as has been asserted by him by way of the information stated by him. Whether it was the volume of the trade which is reflected in the total amount or it was an investment made in the Crypto currency without any withdrawal therefrom would essentially be a matter for consideration upon perusal of the Crypto currency ledger. May be because of this reason, the authority was of the view that the information regarding trade in Crypto currency is not verified. The authority has considered, though in brief, the reply of the petitioner at t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sy involved in this petition are that the petitioner and income tax payee, for the assessment year of 2018-19 submitted his income tax returns and assessment proceedings were drawn. A notice, however, came to be issued by the Assessing Officer on 19.3.2022. Notice Under Sub-Clause (b) of Section 148A of Act, 1961 came to be issued to the petitioner stating that information received suggests that income chargeable to tax for the assessment year 2018-19 has escaped assessment within the meaning of Section 147 of the Act, 1961. Alongwith the said notice, details as part of the annexures were also disclosed that as per higher risk CRIU/VRU information flagged by the Directorate of Income-Tax(systems) which is received insight portal, during ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on. He would submit that a finding that the petitioner has not furnished any documentary evidence in support of information, is perverse as the petitioner had submitted more than one documents. He would further submit that the source of investment has wrongly been held as unverified, though, the entire bank transactions were submitted after obtaining statement from the bank, which was also not disputed. Therefore, it is contended, the impugned order is cryptic, vague, perverse and liable to be interfered with. Though, reply has not been submitted by the respondents, learned counsel for the revenue would submit that the proceedings u/s 148A(b) were initiated against the petitioner because upon receipt of credible information as stated in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... see whether or not, it is fit case to issue a notice u/s 148 of the Act, 1961, by passing order, with the prior approval of specified authority. Sub-Clause (b) of Section 148A of the Act, 1961 thereof provides that the information must suggest that income chargeable to tax has escaped assessment. Therefore, the purpose of enquiry is to find out whether there is material which suggest that income chargeable to tax escaped assessment. The opinion which is required to be found should be based on material available on record. The impugned order as it reads shows that the authority has recorded a finding that the material evidence to verify the transaction regarding Crypto currency is not placed on record. Even in this petition, the pet ..... X X X X Extracts X X X X X X X X Extracts X X X X
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