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A.O. is not only an adjudicator but also an investigator
Case Law Details
- Case Name
- Krishna Shriram Vs Commissioner of Income Tax (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Courts
- All ITAT, ITAT Delhi
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CA Prarthana Jalan
Hon’ble Delhi ITAT while deciding a case involving issue of sec 263 of the Income Tax Act,1961 has held that A.O. is not only an adjudicator but also an investigator.The observation of the Hon’ble bench is as under :-
It is settled law that that frequency and magnitude of transaction are also important factor to decide whether the transaction is business transaction or investment transaction. Now in our considered opinion, the magnitude of share transaction in this case does call for any enquiry o...
Author Info
What kind of investigation training AO is bestowed with is the new question of burden? reason an investigator is some prosecutor when so how can he an adjudicator or judge? i wonder what is the jurisprudence?