Artificial profit/loss arising from client code modification requires transaction-wise reconciliation-Matter restored

Vipul Bansal Vs ITO (ITAT Mumbai) ITAT Mumbai held that artificial profits or losses arising from Client Code Modification in share transactions carried out in F&O segment requires transaction-wise reconciliation. Accordingly, matter restore to the file of AO. Facts- The assessment of the assessee was reopened u/s. 147 of the Act. Accordingly, notice u/s. 148 was issued on 21.09.2016 on the basis of information received from the Directorate of Investigation and Central Intelligence (DIT (I&CI)) through the Additional Commissioner of Income-tax, Range 10(1), Mumbai, alleging that the a...