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RDS Project Limited vs. ACIT (Delhi High Court)
December, 30th 2019

Referred Sections:
Section 148 of the Income Tax Act, 1961
Section 143(3) of the Act
Section 147 of the Act”
Section 68 of the Income-tax Act, 1961,
Section 260A of the Act
Section 14A
Section 43B of the Act

Referred Cases / Judgments:
Pr. Commissioner Of Income Tax -6, New Delhi vs NDR Promoters Pvt. Ltd. vide ITA 49/2018 dated 17.01.2019,
Bombay Stock Exchange Ltd. Vs. Deputy Director of Income Tax (EXEMPTION)
Haryana Acrylic Manufacturing Co. vs. Commissioner of Income Tax and INR., (2009) 308 ITR 38 (DEL),
CIT Vs. Rajesh Jhaveri Stock Broker Pvt. Ltd., (2008) 14 SCC 208,

S. 147 Reopening for taxing bogus share application money: One is known by the company one keeps. As the investors have dubious character & are known to have engaged in the business of providing accommodation entries., the genuineness of their transactions with the assessee has come under serious cloud, giving rise to reasonable belief in the mind of the AO that the assessee may have indulged in a dubious transaction to launder its undisclosed income. The fact that the assessee produced evidence during assessment is neither here nor there (NRA Iron & Steel 412 ITR 161 (SC) followed). Costs of Rs. 2L imposed on assessee for wasting Court's time

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