DCIT v. Modern India Ltd. (2025) 211 ITD 270 (Mum) (Trib.)

S. 147 : Reassessment-Client code modification-Report from Investigation wing–Unexplained Moneys-Bogus commodity trading-Assessee is able to establish that its own funds were utilized to conduct transactions on NSEL platform-Reopening is quashed. [S. 68, 69A, 148]

The assessment was reopened on the basis of  information from Investigating Wing indicating that assessee had indulged in bogus transactions through commodity trading via client code modification On appeal Commissioner (Appeals) held that  all transactions had taken place on NSEL platform and income derived from such transactions had been offered to tax. Reassessment is quashed. On appeal the Tribunal held that  the assessee has established that the assesssee has established that its own funds were utilized to conduct transactions on NSEL platform. Order of the CIT(A) is affirmed. (AY. 2012-13, 2014-15)

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