Client codes modification permissible having no shifting of profits

Brief of the Case

ITAT Mumbai held In the case of ITO vs. M/s Pat Commodity Services P. Ltd. that it is a fact that the movement of prices of commodities cannot be predicted by anyone with accuracy and hence it is inconceivable or unlikely that the assessee could have made profits consistently, even if it is assumed for a moment that the assessee had actually carried out the transactions for its own benefit. We notice that the assessee has offered explanations as to why it carried out the transactions in its own code, i.e. since th

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