Case Law Details
Manoj Anand Vs ACIT (ITAT Panaji)
Introduction: In a recent case before the Income Tax Appellate Tribunal (ITAT) Panaji, an appeal by Manoj Anand against allegations of tax evasion involving colourable devices and sham transactions was dismissed. The case revolved around the conversion of unaccounted money through shell companies to give it the appearance of legitimacy. This article provides a detailed analysis of the case and its implications.
Detailed Analysis: The appeal before the ITAT Panaji stemmed from an order issued by the Commissioner of Income Tax (Appeals)-2, Panaji (CIT(A)), dated January 27, 2022, for the assessment year 2011-12.
Manoj Anand, an individual, had initially declared an income of Rs. 7,50,670 in his income tax return. However, a search and seizure action under Section 132 of the Income Tax Act, 1961, was conducted in his case on October 24, 2017. In response to a notice issued under Section 148, Anand filed an amended return declaring a total income of Rs. 7,50,670. Nevertheless, the Assessing Officer (AO) completed the assessment under Section 143(3) read with Section 147, determining the total income at Rs. 3,20,00,670.
Dissatisfied with the AO’s order, Anand appealed to the CIT(A). The CIT(A) thoroughly examined each aspect of the case and dismissed Anand’s appeal. The CIT(A) pointed out that the case involved the conversion of unaccounted money through shell companies and a series of transactions that created the appearance of legitimate conversion of funds.
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