9911796707
TMI Blog2023 (9) TMI 1227X X X X Extracts X X X X X X X X Extracts X X X X ..... tter is taken up for final hearing today. 2. This petition, under Article 226 of the Constitution of India, challenges the notice dated 28.03.2021 issued under Section 148 of the Income Tax Act for the assessment year 2014-15. 3. Facts in brief would indicate that the petitioner as an individual had filed his original return of income for the assessment year 2014-15 declaring total income of Rs. 4,48,080/- on 11.02.2015. Pursuant to a notice issued under Section 148 of the Act, the petitioner filed return of income of Rs. 4,48,080/- on 15.04.2021 as shown in the original return of income. By the notice impugned in this petition dated 28.03.2021 and the reasons which were supplied to the petitioner on 21.09.2021, in the perception of the R ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ess and ID Proof. 2. Please provide the complete details of transactions of Rs. 2,03,017/- were made with Satish Saraf Group during the F.Y. 2013-14 alongwith copies of ledger accounts, confirmations and nature of transactions. 3. Please provide copies of bank statements maintained by you for the period from 01.04.2013 to 31.03.2014." 4.1 To this notice under section 133(6) of the Act, the petitioner had furnished the details and it was his case that the quantum of transaction of Rs. 2,03,017/- as specified in the notice was made with "Hrim Comtrade" and a copy of ledger account of "Hrim Comtrade" pertaining to financial year 2013-14 relevant to Assessment Year 2014-15 from the books of accounts regularly maintained by him were produce ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... from the office of the DDIT(Inv.), Unit-3(1), Mumbai, the assessee is one of the beneficiary of Satish Saraf Group, managed by Satish Saraf. In his statement recorded u/s. 132(4) of the IT Act, dated 01.10.2013, he stated that, in this business we act as intermediary between two persons or parties who need either conversion of cash into cheques or vice-versa. Once the deal is finalized, each layer of agent/broker will receive a commission for making such exchange possible. The commission depends on the situation & generally varies from 0.05% to 0.25% of the total amount of cash/cheque being converted. The assessee is a beneficiary of Satish Saraf Group and had converted fund of Rs. 2,03,017/- from cash to cheques during the F.Y. 2013-14. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... etails. The details of notices so issued and served are as under:- Section under which the notice was issued Date of issue of notice Date of service of notice Nature of compliance made 148 23.03.2019 23.03.2019 Return of income has been filed on 30.03.2019 143(2) 08.05.2019 08.05.2019 Complied with by filing the letter dated 27.05.2019 and raised the objections against re-opening of the assessment. Furnished further details vide letter dated 27.06.2019. 142(1) 13.05.2019 14.05.2019 Letter 14.06.2019 14.06.2019 Order disposing the objections was passed and e-mailed to the assessee 142(1) 09.09.2019 11.09.2019 Complied with by filing the details vide letter dated 25.09.2019 3. The details filed from time to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eturn of income filed u/s. 148 of the Act. 4. Subject to above verification of the issues involved in the re-assessment proceedings as per the reasons recorded u/s 148 of the Act, total income of the assessee is computed as under:- Sr. No. Particulars of income Amount. 1. Profit of the business Rs. 20,876/- 2. Income from other sources: As per statement Rs. 4,43,739/- Gross Total income Rs. 4,64,615/- 3. Deductions u/s. 80C, 80CCF and 80D of the Act as per statement Rs. 1,30,228/- Total income computed u/s, 143(3) r.w.s. 147 of the Act Rs. 3,34,387/- Total income rounded to Rs. 3,34,390/- (Rupees Three Lakhs Thirty Four Thousand Three Hundred Ninety only) 6.3 Therefore, even in the earlier round, ..... X X X X Extracts X X X X X X X X Extracts X X X X
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