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3. Therefore, the case of the assesse was reopened by issuing of notice u/s 148 dated 30.03.2019 on the basis of aforesaid information in the ITD assessment under NMS (non-filer) category, that the assesse had not filed its return of income for assessment year 2012-13. The A.O observed from the data as per ITD database that the assesse had entered into purchase and sale of equities on stock exchanges/commodities exchanges, however, the capital gain income P a g e |3 DCIT (IT)-3(1)(2) Vs. M/s Lazard Asset Management LLC from the sale of the said investment by the assesse was not shown since the assesse had not filed return of income for the year.