above transactions, the Assessing Officer has
propounded the theory of circuitous transactions among the concerns
for diverting profit of LJM in the guise of payment ... found that the AO has propounded a theory of circuitous
transactions purely on conjectures and surmises, moreover without
their being proper appreciation of facts
assessee
asses
used 'shell entities' for rotation of funds/circuitous transactions.
The Assessing Officer identified expenses related to the shell entities
including interest ... assessee had used said shell entities for
rotation of funds/circuitous
funds/circuitous transactions in order to and
creation of fictitious asset. On perusal
Smt. Amita Mittal , Ropar vs Department Of Income Tax
IN THE INCOME TAX APPELLATE TRIBUNAL
money invested in
LJM and according to him, the assessee has circuitous
transactions among certain firms with the motive of diverting
funds ... purpose of
29 I.T.A. No.3374/CHNY/2019
circuitous transactions to divert the funds of LJM to the
assessee, to explain sources
sought to explain the above amount through the
lengthy and circuitous transactions, the commercial substance/
economic rationale for such transaction has not been
satisfactorily explained ... sought to explain
the above amount through the lengthy and circuitous
transactions, the commercial substance/ economic rationale for
such transaction has not been satisfactorily explained
Wellknown Polyester Ltd. Though the modus operandi of circuitous transactions was
narrated by the group directors of the said companies, the said circuitous transaction*
were ... modus operandi disclosed at
the time of search in respect of circuitous transactions without discharging its primary
onus to prove the source of share capital
Authority. It is submitted that the transaction of
assignment dated 01.03.2019 was not bonafide transaction and the
transaction was entered into by Reliance Infrastructure only ... paid by it to Reliance Infrastructure Ltd. is
outcome of a circuitous transaction with the Reliance group companies.
It is submitted that after receiving
showing the alleged misappropriation of
9
Manoj's money through circuitous transactions (money laundering), the
charge sheet was rightly submitted against the petitioners ... alleged financial misappropriation evidenced
by bank statements and the ledger, the circuitous transactions
suggesting money laundering, and the petitioners' non-cooperation with
the investigation
Jatinder Mohan Mittal, Huf, Chandigarh vs Department Of Income Tax
IN THE INCOME TAX APPELLATE
Authority. It is submitted that the transaction of
assignment dated 01.03.2019 was not bonafide transaction and the
transaction was entered into by Reliance Infrastructure only ... paid by it to Reliance Infrastructure Ltd. is
outcome of a circuitous transaction with the Reliance group companies.
It is submitted that after receiving
