Chintan Jaswantbhai Shah v. ITO (2021) 87 ITR 228 (Ahd.)(Trib.)

S. 147 : Reassessment-With in four years-Information from Investigation Wing-Client code modification-Mistake by share broker-Reassessment is held to be not valid. [S. 148]

Tribunal held that there was no whisper in the order of the authorities that there was cash transfer between the parties for transferring the income of the assessee to the other party. Thus, in the absence of such verification or examination carried out by the authorities, the Assessing Officer was directed to delete the addition made by him. Since the code of the other party was entered at the place of the assessee, the other party was also required to be investigated.  Followed Rakesh Gupta v. CIT (2018) 405 ITR 213 (P& H) (HC)  (AY.2009-10)