Section 148 Notice Quashed as Change of Opinion; Section 68 Fails on Merits

ACIT Vs Arun Kumar (ITAT Delhi) Sale of Shares Through SEBI Broker, Tax Paid—No Scope for s.68 Addition – Notice u/s 148 Violates Asian Paints Rule- Revenue’s Appeal Dismissed Revenue appealed against deletion of addition of Rs.57,06,000/- made by AO u/s 68 on alleged penny stock transactions in shares of City Travel Solutions Ltd. Assessee had purchased 19,000 shares in April 2013 for Rs.11,86,972/- & sold them in March 2014 through Reliance Securities Ltd, a SEBI-registered broker, receiving net sale proceeds of Rs.56,94,882/-. Assessee had already declared Rs.45,08,090/- as S...