Spicy Sangria Hotels (P) Ltd v ITO (2020) 268 Taxman 360 (HC) (Bom.)(HC)

S. 147 : Reassessment–After the expiry of four years- Information from DDIT (investigation)–Purchasing and selling of shares- Systematic evasion of taxes by clients by misuse of NMCE platform–Reassessment notice is held to be justified. [S.143(1), Art.226]

Dismissing the petition the Court held that as per the information from DDIT (investigation) it was found that the assessee is  purchasing and selling of shares in systematic evasion of taxes by clients  by misuse of NMCE platform.  Accordingly the issue of reassessment notice is held to be justified as the AO has formed a prima facie view that income chargeable to tax has escaped the assessment which was accepted u/s 143(1) of the Act. (AY. 2012-13)