2008-09
Beneficiary Beneficiary Beneficiary
Client Client
When Original When Modified Net Reduction
Client Client in Income due
(Ascertained (Ascertained to CCM (In
Profit Shifted ... codes modifications so as to facilitate losses and profits to the
clients as per the requirement. He observed that the complete data of the client
client codes at the time of transactions. To rectify the error in
punching of client code, a facility known as 'Client Code Modification ... punching of client
codes. In order to rectify the punching of client code, a facility i.e.
Client Code Modification (in short CCM) is provided
client or broker
and that there was no intention of shifting of profit / losses, hence, the
AO held that client code modification to be malafide ... reason to believe that certain clients were benefited by
their brokers using the method of Client Code
Modification. The report to this effect
modus
operandi adopted Share Brokers during
Modification of Client Code to manipulate
income/loss of their clients. The investigation
team has conducted surveys ... were carried out from
assessee's client code then subsequently
client code was modified to other client the
details of such case
unique code which is
assigned by a broker to its clients. A broker can issued just one
code to a client. Client Code Modification means ... modification
of client code after the execution of trade.
Over a period of time, some persons, in connivance with brokers
started using Client Code Modifications
different client/beneficiaries, according to their
requirements to enhance or reduce the tax liability. The
Directorate obtained client code modification (CCM) data ... such that the original client code/name and the modified client
code/name are similar to each other.
ii) Modification within relatives.
iii) Any similar
code modification in
number of trades contracts involving different clients during FY
2009-10 to 2011-12 and the total amount involved in client code ... typing such that original client code/name and the
modified client code/name are similar to each other.
[2] Modification within relatives.
[3] Any similar
specify as to
what was the client code of the assessee and which was the client code
which was modified so as to generate ... which is the client code modifications which have been modified to
which transactions modifications have been done and when such
modifications have been done
code modification and therefore, on the basis of
such circular, it must be held that errors in punching in the
client's code ... that revised Client
Code Modification timing w.e.f. Saturday 9th July 2011 as under:
a. The facility of client code modifications is allowed
dispute that the client code modifications had taken place in the case of the
petitioner. This modification facility is used by some brokers to transfer ... Officer for
re-adjudication for the limited purpose of verifying the client code
modifications are wrong and denied. The Tribunal has remanded the issue