ITAT DELHI BENCH ‘F
ITA No. 5070/Del/2012
Assessment Year : 2002–03
M/s Ramji Dass Darshan Kumar Ltd.
Vs.
Income Tax Officer
ORDER
PER G.D.AGRAWAL, VP:
This appeal by the assessee is directed against the order of learned CIT(A)-XVIII, New Delhi dated 19th July, 2012 for the AY 2002- 03.
2. Ground Nos.1 to 4 of the assessee’s appeal are against the reopening of assessment under Section 147 of the Income-tax Act, 1961. In the assessment order, the Assessing Officer has recorded that in this case, the original return furnished by the assessee was processed under Section 143(1) and no regular assessment had taken place. The Assessing Officer had received the information from DIT(Investigation) that during the course of investigation, it was found that Mukesh Gupta along with his relatives and associate concerns were in the business of providing entries by way of loans, share application money, gifts etc. As per information, the assessee was also beneficiary of the entry of 5 lakhs taken from Suma Finance Investment Ltd. In view of the above specific information, the Assessing Officer recorded the satisfaction for reopening of assessment under Section 148 and after issuing notice under Section 148, reopened the assessment.
3. At the time of hearing before us, the learned counsel for the assessee could not justify how the reopening of assessment was invalid.
4. In view of the above, we do not find any merit in ground Nos.1 to 4 of the assessee’s appeal. The same are rejected.
5. Ground Nos.5 & 6 of the assessee’s appeal are against the addition of ~16 lakhs made by the Assessing Officer as undisclosed income.
6. At the time of hearing before us, it was stated by the learned counsel that though the assessment was reopened on the ground of escapement of income of 5 lakhs being alleged entry taken from Suma Finance Investment Ltd., the Assessing Officer made the addition of ~16 lakhs on the ground that the assessee has taken the total loan of ~16 lakhs from following persons:-
