TULIP ENGINEERING PVT LTD Vs. INCOME TAX OFFICER

JUDGEMENT

(1.) THE assessee is in appeal before us and challenges an order of the Income Tax Appellate Tribunal (hereafter referred to as "ITAT") dated 30.06.2014 in ITA 410/Del/2013.

(2.) THE assessee was subjected to re -assessment proceedings; the initiation of which has been challenged under Section 147. The second ground urged is with respect to the absence of notice under Section 143 (2) and the third is with respect to the merits of addition of Rs.4,84,000/ -.

(3.) BRIEFLY , the facts are that for AY 2008 -09, the assessee had reported an income of Rs.444/ -. This was processed under Section 143 (1). Upon an enquiry and investigation report, the AO issued notice under Section 148, doubting a transaction based upon the transfer of shares and purchase by two subsequent transferees i.e. Raghubir Singh and Simranjeet Kaur. The assessment was completed with the addition of that amount to the assessee's final income. The matter was carried in appeal unsuccessfully to the CIT (A), and later, to the ITAT as well. The assessee was unable to persuade both the authorities to accept its submissions that the reassessment proceedings were without jurisdiction. On the merits as well, the ITAT confirmed the view of the Assessing Officer and the CIT (A) that the amount had to be added to the assessee's income and brought to tax.