Omni Lens (P.) Ltd. v. ACIT (2023) 291 Taxman 619 (Guj)(HC)

S. 147 : Reassessment-With in four years-Unexplained investment-Laundering of huge funds-Rotation of funds-Reassessment notice and order disposing the objection is justified [S. 69B, 148, Art. 226]

One NK Proteins Ltd. became a member of NSEL in 2008 and executed rotation trades whereby the margin profit would eventually be credited back to its account. The investment to carry out such trades being unexplained, the transaction quite possibly was deemed to launder unaccounted money only. The assessee was providing accommodation entries and could not disclose the source of investment and failed to disclose fully all material facts before the AO. Only brokers’ ledgers and bank statements were provided whereas many details such as Demat accounts were asked for. The reasons expressly noted the modus operandi of the NK group and the order on objections was a well-reasoned order. Petition  was dismissed. (AY. 2013-14, 2014-15)