Contrived losses by using Client Code Modification not proved, loss disallowance deleted

Canara Securities Ltd. Vs DCIT (ITAT Hyderabad) ITAT Hyderabad held that no records brought suggesting that assessee has contrived losses by using Client Code Modification. Thus, disallowance of losses only on presumption is not justifiable. Accordingly, disallowance deleted. Facts- The assessee, engaged in the business of investment banking i.e. purchase and sale of securities in equity segment and futures & option segment. AO received specific information that the assessee had contrived losses by using Client Code Modification (CCM) facility and based on the information, AO reopened the ...