Case Law Details
Rochana Agarwal Vs ACIT (Allahabad High Court)
The reason for issuing the notice under Section 148 of the Act is that during investigation, the Assessing Officer has gone through the income tax return and other related documents of the assessee and has found that the M/s KCGP Share Broking Service Pvt. Ltd. has been used to provide bogus accommodation entries to various beneficiaries. The assessee is one of the beneficiaries of M/s KCGP Share Broking Services Pvt. Ltd., which is engaged in providing accommodation entries to the beneficiaries. The assessee is a beneficiary of receiving bogus accommodation entries to the tune of Rs. 6,94,540/-. The ACIT has expressed the view that the assessee has introduced her own undisclosed income in her books of account by way of accommodation entries by showing artificial transactions to make the same valid transactions, though it is simply a planning to introduce unexplained money amounting to Rs. 6,94,540/- into books of account. After considering the report of the Assistant Director of Income Tax (Inv.), Unit-3(3), Kolkata and the material available on record, the ACIT recorded that he has reason to believe that the income amounting to Rs. 6,94,540/- has escaped assessment in respect of the assessee. Hence the issuance of notice under Section 148 of the Act was deemed fit.
By means of the earlier notice dated 16-05-2019 issued under Section 133 (6) of the Act regarding the case of the petitioner for the assessment year 2017-18, the Assessing Officer had merely called for the following informations :-
(i) copy of DEMAT A/c and substantiate that the entire profit on sale of scripts was offered to tax.
(ii) Financial ledger for F.Y. 2014-15 showing all transactions related to shares.
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