Mere reproduction of conclusions of investigation report in own words by AO is borrowed satisfaction
Case Law Details
Case Name : Assistant Commissioner of Income Tax Vs M. K. Wood India Pvt. Ltd. (ITAT Delhi)
Related Assessment Year : 2011-12
Courts :
All ITAT ITAT Delhi
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ACIT Vs M. K. Wood India Pvt. Ltd. (ITAT Delhi)
In the case in hand based upon the statement of Kishori Saran Goel, recorded u/s 131 of the Act during the course of search of proceedings upon M/s. Spaze Group on 17.02.2016 the ld. AO made a conclusion that assessee had received accommodation entries. However, there is not a word in this reasons that what were the nature of accommodation entries because it is not a case of unexplained cash credits but a bogus sale. How the return filed reflected a possible escape of income. The reasons as recorded by the Ld. AO has no discussion of the material...
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