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Joginder Pal Singh, New Delhi vs Ito Ward 16(4), New Delhi on 12 April, 2023

(f) Absolutely no independent enquiry was indeed carried out by the Ld. AO as to whether the assessee had per se claimed any loss in the sum of Rs.10,09,250/- in his return of income. From the computation of income enclosed by the assessee along with return of income which are also enclosed in pages 2 and 6 of PB, we find that assessee had only earned profit from its share transactions to the tune of Page 12 of 16 ITA No.2876/Del/2019 Joginder Pal Singh vs. ITO Rs.73,40,121/- and had not incurred any loss at all. Hence, there is absolutely no claim of loss of Rs.10,09,250/- by the assessee in his F&O Segment, whether fictitious or otherwise. This fact was not even verified by the Ld. AO while recording reasons for formation of belief that income of the assessee had escaped assessment. Hence the reasons recorded by the Ld. AO does not have live link to form a belief that income of the assessee had escaped assessment. Similar is the case of Ld. Addl. CIT/Ld. PCIT while according their respective approvals u/s 151 of the Act.
Income Tax Appellate Tribunal - Delhi Cites 10 - Cited by 0 - Full Document

Smt. Basanti Bai Agrawal, ... vs Income Tax Officer, Ward-Mahasamund, ... on 23 June, 2025

Smt. Basanti Bai Agrawal Vs. ITO, Ward-Mahasamund ITA No.259/RPR/2025 6 Smt. Basanti Bai Agrawal Vs. ITO, Ward-Mahasamund ITA No.259/RPR/2025 7 Smt. Basanti Bai Agrawal Vs. ITO, Ward-Mahasamund ITA No.259/RPR/2025 8 Smt. Basanti Bai Agrawal Vs. ITO, Ward-Mahasamund ITA No.259/RPR/2025 9 Smt. Basanti Bai Agrawal Vs. ITO, Ward-Mahasamund ITA No.259/RPR/2025 10 Smt. Basanti Bai Agrawal Vs. ITO, Ward-Mahasamund ITA No.259/RPR/2025 11 Smt. Basanti Bai Agrawal Vs. ITO, Ward-Mahasamund
Income Tax Appellate Tribunal - Raipur Cites 12 - Cited by 0 - Full Document
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