Amandeep Singh Vs DCIT (ITAT Delhi)
ITAT Delhi held that initiated the reassessment proceedings under section 148 of the Income Tax Act only on the basis of suspicion of involvement in money laundering activity without cogent material brought is bad-in-law. Accordingly, appeal allowed.
Facts- The assessee filed its return of income on 14.10.2010 declaring total income of Rs.10,97,140/-. Subsequently, proceedings were initiated u/s. 148 of the Income-tax Act. Accordingly, notice u/s 148 was issued and served on the assessee on 31.03.2017 after obtaining approval from Pr.CIT-4, New Delhi. Based on the information received from DDIT (Inv.), AO observed that large scale transactions are carried out between sister concerns through a number of accounts. The transactions were found to be without any economic rationale and it is suspected that money laundering activities were being carried out through these accounts. Further he observed that it is suspected Mr. Tarun Goyal, CA operating from Karol Bagh, New Delhi is involved in purchase of existing companies and formation of new ones. It was found that he was controlling 35 companies.
CIT(A) dismissed the appeal. Being aggrieved, the present appeal is filed.
Conclusion- Held that the AO has not brought on record any cogent material linking the assessee and Tarun Goyal while recording the reasons. He initiated the proceedings only on the basis of suspicion and no cogent material brought on record linking the assessee any way in these transactions.
