ACIT v. G R D Commodities Ltd. (2021) 188 ITD 793 (Kol.)(Trib.)

S. 147 : Reassessment-After the expiry of four years-Derivative losses-Report of Investigation Directorate-Commodities transaction-Reassessment notice was held to be not justified. [S. 4, 143(3), 148, 153A]

Held that the Assessing Officer had not independently applied his mind to information received from Investigation Directorate regarding assessee’s commodity transactions but had simply recorded reasons based on borrowed satisfaction. On facts notice of reassessment was quashed. (AY. 2009-10 to 2012-13, 2014-15)