No reopening of Assessment for mere client code modification

Stratagem Portfolio (P.) Ltd. Vs. DCIT (ITAT Delhi)

Conclusion: Since there was no material to infer that client code modification had been done by assessee with malafide purpose of shifting of the profit or evasion of the tax hence, assessment could not be reopened under section 147 in absence of any tangible material to infer that income escaped in the case of assessee.

Held: AO had completed assessment in terms of section 147 after making addition under section 68 and 69C  on the reason that  client code modifi

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