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“Section 133(6)”

Section References (mined)Section 133Section 133(6)6,687 judgments

The decision most relied on for Section 133(6) is CIT v. Simit P. Sheth (356 ITR 451), cited in 1,465 judgments on BharatTax.

Leading authorities on Section 133(6)

CIT v. Simit P. Sheth
356 ITR 451 · 2013 · High Court
1,465
citing judgments

Additions for alleged bogus purchases should be restricted to the profit element, not the entire turnover. The profit element is often estimated at 12.5% of the purported bogus purchases.

CIT v. Orissa Corporation Pvt. Ltd.
159 ITR 78 · 1986 · Supreme Court
897
citing judgments

When an assessee provides the identity and address of a creditor or investor for a cash credit or share capital under Section 68, the burden shifts to the Department to establish lack of genuineness or creditworthiness, requiring it to conduct further inquiries; mere non-compliance by third parties to summons cannot be the sole basis for an adverse inference against the assessee.

Raymond Woollen Mills Ltd. v. ITO
236 ITR 34 · 1999 · Supreme Court
862
citing judgments

For reassessment proceedings under Section 148, the Assessing Officer only needs prima facie material to have a reason to believe income has escaped assessment. Conclusive proof or evaluation of the sufficiency and correctness of such material is not required at the stage of issuing the notice.

CIT v. Lovely Exports (P) Ltd.
216 CTR 195 · 2008 · Supreme Court
854
citing judgments

If an assessee company receives share application money from alleged bogus shareholders and provides their details to the Assessing Officer, no addition can be made under Section 68 in the company's hands; the Department must proceed against the shareholders by reopening their individual assessments.

CIT v. Tata Elxsi Ltd.
349 ITR 98 · 2012 · High Court
818
citing judgments

When computing deduction under Section 10A, if communication or telecommunication expenses are excluded from export turnover, they must also be excluded from total turnover to maintain consistency and apply the ordinary meaning of 'turnover' in context.

CIT v. Bholanath Poly Fab. Pvt. Ltd.
355 ITR 290 · 2013 · High Court
712
citing judgments

If an assessee makes purchases from bogus parties, but the underlying goods are genuinely acquired and sold, only the profit margin embedded in such purchases, and not the entire value of the bogus purchases, should be added to the assessee's income.

(Central)-1 v. NRA Iron & Steel (P) Ltd.
103 Taxmann.com 48 · 2019 · Supreme Court
696
citing judgments

When assessing cash credits, share capital, or loans, the assessee bears the onus to prove the identity, creditworthiness, and genuineness of transactions. This burden is not discharged merely by documentary evidence if field inquiries reveal accommodation entries or dealings with paper/shell companies.

CIT v. Daulat Ram Rawatmull
87 ITR 349 · 1973 · Supreme Court
525
citing judgments

The onus to prove that an apparent transaction or explanation is not real lies with the person who claims it to be so. If an assessee provides a plausible explanation for a transaction, the revenue must establish that the apparent transaction is not genuine.

Judgments citing Section 133(6)

Kailash Judhistir Sahu, Mumbai vs. CIT (A)-38, Mumbai

In the result, both the appeals filed by the Assessee are partly allowed in the same terms

ITA 1636/MUM/2023[2010-11]Status: DisposedITAT Mumbai10 Oct 2023AY 2010-11
For Appellant: Shri Ashwin Chhag, Ld. CAFor Respondent: Shri Anurag Tripathi, Ld. Sr
Section 133(6)Section 142(1)Section 250

IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH, MUMBAI SHRI N. K. CHOUDHRY, JM 1. I.T.A. No. 1636/Mum/2023 (Assessment Year

ACIT, Circle-63(1), New Delhi vs. Friends Medicos, New Delhi

ITA 8709/DEL/2019[2015-16]Status: DisposedITAT Delhi10 Oct 2023AY 2015-16

Bench: Sh. N.K.Billaiya & Sh. Anubhav Sharmaacit, Vs. Friends Medicos Circle-63(1), Shop No. 6, Mcd Shopping New Delhi Complex, Asaf Ali Road, New Delhi-110055 Pan : Aaaff9675Q (Appellant) (Respondent)

Section 133ASection 143(2)Section 143(3)Section 145(3)

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI (DELHI BENCH ‘B’ : NEW DELHI) BEFORE SH. N.K.BILLAIYA, ACCOUNTANT MEMBER AND SH. ANUBHAV

Sibasankar Sahu, - Deogarh vs. PCIT, Sambalpur

In the result, appeal of the assessee is allowed

ITA 217/CTK/2022[2017-18]Status: DisposedITAT Cuttack09 Oct 2023AY 2017-18

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अऩीऱ सं/Ita No.217/Ctk/2022 (ननधाारण वषा / Assessment Year : 2017-2018) Sibasankar Sahu, Vs Pr.Cit, Sambalpur Arnapurna Store, At: Bania Sahi, Po/Ps: Deogarh Dist-Deogarh-768108 Pan No. :Apeps 1706 E (अऩीऱाथी /Appellant) .. (प्रत्यथी / Respondent) ननधााररती की ओर से /Assessee By : Shri P.K.Mishra, Advocate राजस्व की ओर से /Revenue By : Shri Abani Kanta Nayak, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 09/10/2023 घोषणा की तारीख/Date Of Pronouncement : 09/10/2023 आदेश / O R D E R Per Bench : This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Pr.Cit, Sambalpur, Dated 18.03.2022, Passed In Itba/Rev/F/Rev5/2021-22/1041011837(1) For The Assessment Year 2017-2018. 2. It Was Submitted By The Ld. Ar That The Appeal Filed By The Assessee Is Delayed By 199 Days. It Was The Submission That The Delay Was On Account Of Medical Treatment Of The Assessee’S Father & Assessee’S Wife. It Was The Submission That The Assessee Is An Individual Engaged In Trading Of Potatoes, Onion & Garlic In The Remote Area Of The District Of Deogarh, Odisha. It Was The Submission That The Assessee Was Not Well- Versed In Taxation Issues & On Account Of The Medical Treatment Of The 2 Assessee’S Father As Also The Assessee’S Wife, The Assessee Could Not File

For Appellant: Shri P.K.Mishra, AdvocateFor Respondent: Shri Abani Kanta Nayak, CIT-DR
Section 144Section 144ASection 263Section 44A

आयकर अऩीऱीय अधधकरण, कटक न्यायऩीठ,कटक IN THE INCOME TAX APPELLATE TRIBUNAL CUTTACK BENCH CUTTACK श्री जाजज माथन, न्याययक सदस्य

ITO-20(3)(1), Mumbai vs. Saheb Ali Khan, Mumbai

In the result, the appeal by the Revenue is dismissed

ITA 2128/MUM/2023[2010-2011]Status: DisposedITAT Mumbai09 Oct 2023AY 2010-2011

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: NoneFor Respondent: Shri Ram Krishna Kedia
Section 133(6)Section 143(1)Section 147Section 148Section 250

with various parties for purchases of goods/materials. In order to verify the correctness and genuineness of the transaction, notices under section 133(6) of the Act were issued to these parties at the address available on record and to submit documentary evidence in respect of transactions entered with the assessee ... However, notices issued under section 133(6) of the Act were returned unserved by the postal authorities with the remark „not known/left/no such address‟ etc. Accordingly, the assessee was asked to furnish a copy of the ledger account, invoices, delivery challans, lorry receipts, bank statements, octroi receipts, goods receipts

M/S.Winsel Aquas Private Limited, Mumbai vs. Income Tax Officer 11(3)(4), Mumbai

In the result, the appeal by the assessee for the assessment year 2010-

ITA 1163/MUM/2019[2010-11]Status: DisposedITAT Mumbai09 Oct 2023AY 2010-11

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Rakesh KapoorFor Respondent: Shri Ram Krishna Kedia
Section 143(1)Section 143(3)Section 147Section 254(1)Section 37(1)

agreement with Pepsi Foods Private Ltd. In response thereto, the assessee filed correspondences with PepsiCo India Holdings Pvt. Ltd. dated 26/12/2012. Notice under section 133 (6) of the Act was also issued to Pepsi Foods Private Ltd calling for various information. As the said notice was not complied with ... existence to make the Royalty payment to Pepsi Foods Private Ltd. The learned DR further submitted that neither the notice issued under section 133(6) of the Act to Pepsi Foods Private Ltd was complied nor the assessee produced the said party before the lower authorities. Accordingly, the learned

M/S.Winsel Aquas Private Limited, Mumbai vs. Income Tax Officer 11(3)(4), Mumbai

In the result, the appeal by the assessee for the assessment year 2010-

ITA 1162/MUM/2019[2011-12]Status: DisposedITAT Mumbai09 Oct 2023AY 2011-12

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Rakesh KapoorFor Respondent: Shri Ram Krishna Kedia
Section 143(1)Section 143(3)Section 147Section 254(1)Section 37(1)

agreement with Pepsi Foods Private Ltd. In response thereto, the assessee filed correspondences with PepsiCo India Holdings Pvt. Ltd. dated 26/12/2012. Notice under section 133 (6) of the Act was also issued to Pepsi Foods Private Ltd calling for various information. As the said notice was not complied with ... existence to make the Royalty payment to Pepsi Foods Private Ltd. The learned DR further submitted that neither the notice issued under section 133(6) of the Act to Pepsi Foods Private Ltd was complied nor the assessee produced the said party before the lower authorities. Accordingly, the learned

Income Tax Officer 11(2)(1), Mumbai vs. Satguru Corporate Services Private Limited, Mumbai

In the result, the appeal of the Revenue

ITA 878/MUM/2018[2012-13]Status: DisposedITAT Mumbai09 Oct 2023AY 2012-13

Bench: Shri Om Prakash Kant () & Shri Pavan Kumar Gadale () Assessment Year: 2012-13 M/S Satguru Corporate Services Ito, 11(1)(3), Pvt. Ltd., Aayakar Bhavan, 4Th Vs. 5Th Floor, Sunteck Centre, 37-40 Floor, Mumbai. Subhash Road, Vile Parle (East), Mumbai-400057. Pan No. Aapcs 2160 R Appellant Respondent Assessment Year: 2012-13 Ito, 11(1)(3), M/S Satguru Corporate Services Pvt. Room No. 201, Aayakar Ltd., Vs. Bhavan, M.K. Marg, 5Th Floor, Sunteck Centre, 37-40 Mumbai-400020. Subhash Road, Vile Parle (East), Mumbai-400057. Pan No. Aapcs 2160 R Appellant Respondent

For Appellant: Mr. Rakesh JoshiFor Respondent: Mr. Dr. Kishor Dhule, CIT-DR
Section 69

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “G” MUMBAI BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND SHRI PAVAN

Satguru Corporate Services Private Limited, Mumbai vs. Income Tax Officer 11(1)(3), Mumbai

In the result, the appeal of the Revenue

ITA 483/MUM/2018[2012-13]Status: DisposedITAT Mumbai09 Oct 2023AY 2012-13

Bench: Shri Om Prakash Kant () & Shri Pavan Kumar Gadale () Assessment Year: 2012-13 M/S Satguru Corporate Services Ito, 11(1)(3), Pvt. Ltd., Aayakar Bhavan, 4Th Vs. 5Th Floor, Sunteck Centre, 37-40 Floor, Mumbai. Subhash Road, Vile Parle (East), Mumbai-400057. Pan No. Aapcs 2160 R Appellant Respondent Assessment Year: 2012-13 Ito, 11(1)(3), M/S Satguru Corporate Services Pvt. Room No. 201, Aayakar Ltd., Vs. Bhavan, M.K. Marg, 5Th Floor, Sunteck Centre, 37-40 Mumbai-400020. Subhash Road, Vile Parle (East), Mumbai-400057. Pan No. Aapcs 2160 R Appellant Respondent

For Appellant: Mr. Rakesh JoshiFor Respondent: Mr. Dr. Kishor Dhule, CIT-DR
Section 69

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “G” MUMBAI BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND SHRI PAVAN

Aaa Teleshopping Pvt Ltd, New Delhi vs. ACIT Circle-1(1), New Delhi

In the result, appeal of the assessee is dismissed

ITA 9633/DEL/2019[2011-12]Status: DisposedITAT Delhi09 Oct 2023AY 2011-12

Bench: Sh. G. S. Pannu & Shri Chandra Mohan Gargaaa Teleshopping Pvt. Vs. The Acit Ltd., 199, Rajdhani Circle – 1(1) Enclave, Pitampura, New Delhi New Delhi – 110 034 Pan No. Aafca 3709 E (Appellant) (Respondent) Assessee By --None-- Revenue By Ms. Anubhaa Tah, Sr. D.R. Date Of Hearing: 04.10.2023 Date Of Pronouncement: 09.10.2023 Order Per Chandra Mohan Garg, Jm :

Section 69Section 69C

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘A’, NEW DELHI BEFORE SH. G. S. PANNU, PRESIDENT AND SHRI CHANDRA

Acumen Infrastructure Private Limited, New Delhi vs. ACIT Circle-1(2), New Delhi

In the result, appeal of assessee is dismissed

ITA 8702/DEL/2019[2016-17]Status: DisposedITAT Delhi09 Oct 2023AY 2016-17

Bench: Sh. G. S. Pannu & Shri Chandra Mohan Gargacumen Infrastructure Vs. The Acit Private Ltd. Circle – 1(2) C/O. Hote Oyster, B/H Ibp Delhi Pump, Near Big Bazar, Surat, Dumas Road, Piplod, Surat – 395 007 Pan No. Aafca 2256 G (Appellant) (Respondent) Assessee By --None-- Revenue By Ms. Anubhaa Tah, Sr. D.R. Date Of Hearing: 04.10.2023 Date Of Pronouncement: 09.10.2023

Section 40Section 68

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘A’, NEW DELHI BEFORE SH. G. S. PANNU, PRESIDENT AND SHRI CHANDRA

Delphi Automotive Systems (P) Ltd, New Delhi vs. Deputy Commissioner of Income-Tax, New Delhi

In the result, the appeal of the assessee is partly allowed for statistical purposes

ITA 1361/DEL/2015[2010-11]Status: DisposedITAT Delhi09 Oct 2023AY 2010-11

Bench: Shri M. Balaganesh & Shri Anubhav Sharmaaptive Components India P. Ltd, Vs. Deputy Commissioner (Formerly Known As Delphi Of Income-Tax, Automotive Systems P. Ltd), Circle-7(1), P-24, Green Park Extension, New Delhi South Delhi, New Delhi-110016 (Appellant) (Respondent) Pan:Aaacd0226E

For Appellant: Sh. Neeraj Jain, AdvFor Respondent: Sh. Rajesh Kumar, CIT DR
Section 143(3)Section 144CSection 92CSection 92C(2)

INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “I”: NEW DELHI BEFORE SHRI M. BALAGANESH, ACCOUNTANT MEMBER AND SHRI ANUBHAV SHARMA, JUDICIAL

Shashi Sharma, Ghaziabad vs. DCIT, Central Circle, Ghaziabad

In the result, the appeal of the assessee is allowed

ITA 1841/DEL/2022[2016-17]Status: DisposedITAT Delhi06 Oct 2023AY 2016-17

Bench: Sh. C. M. Gargdr. B. R. R. Kumarita No. 1841/Del/2022 : Asstt. Year : 2016-17 Shashi Sharma, Vs Dcit, Ka-5, Kavi Nagar, Central Circle, Ghaziabad-201001 Ghaziabad (Appellant) (Respondent) Pan No. Ageps6394R

For Appellant: Sh. Rajiv Khandelwal, CA &For Respondent: Mr. Waseem Arshad, CIT DR
Section 132Section 133(6)Section 139(1)Section 142(1)Section 143(2)Section 153ASection 234ASection 271(1)(c)Section 68

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘C’, NEW DELHI Before Sh. C. M. Garg, Judicial Member Dr. B

Gudwala & Sons, Delhi vs. ACIT, Central Circle- 4, New Delhi

In the result, the appeal of the assessee is allowed

ITA 1919/DEL/2018[2015-16]Status: DisposedITAT Delhi06 Oct 2023AY 2015-16

Bench: Shri Chandra Mohan Garg & Shri Pradip Kumar Kedia

For Appellant: Shri Vishal Kalra, AdvFor Respondent: Shri Anuj Garg, Sr.DR
Section 131Section 132Section 133(6)Section 139(1)Section 143(3)Section 69A

course of the assessment proceedings, the Assessing Officer inter alia made inquiries towards purchase transactions reported by the assessee. Notices under section 133(6) and also summons under Section 131 of the Act were issued to several parties as listed in the assessment order. The Assessing Officer eventually observed that ... that one of the parties namely, Shri Arun Yadav has not responded to notice under Section 133(6) of the Act which was returned unserved. Likewise, another party namely, Ms. Nisha Sharma also did not respond to the notice under Section 133(6) of the Act. Dissatisfied with the documentary

Computer Sciences Corporation India Private Limited, Chennai vs. ACIT, Chennai

ITA 1654/CHNY/2011[2007-08]Status: DisposedITAT Indore06 Oct 2023AY 2007-08

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2007-08 Computer Sciences Acit, Corporation India Private Company Circle 1(3), Limited, Chennai [Formerly Covansys (India) Private Limited], बनाम/ Unit 13, Block 2, Sdf Buildings, Vs. Madras Export Processing Zone, Tambaram, Chennai (Assessee / Appellant) (Revenue / Respondent) Pan: Aaacc1351M Assessee By Shri Neeraj Jain, Adv. Shri Abhishek Agrawal, Ca Revenue By Shri P.K. Mishra, Cit Dr Date Of Hearing 12.07.2023 Date Of Pronouncement

Section 10ASection 143(2)Section 143(3)Section 144C(5)Section 14ASection 92C

length. 8. The ld. AO and Hon'ble DRP erred in law and in facts by exercising his powers under section 133(6) of the Act to obtain information which was not Page 3 of 47 Computer Sciences Corporation India Private Limited, Chennai Assessment year 2007-08 available in public

Manohar Singh, Jodhpur vs. ITO, Ward-1(3), Jodhpur

In the result, the appeal of the assessee is partly allowed

ITA 159/JODH/2019[2013-14]Status: DisposedITAT Jodhpur04 Oct 2023AY 2013-14
Section 143(2)Section 144Section 234ASection 234BSection 271(1)(b)

deemed it fit to verify the veracity of the submission made by the assessee by invoking the provision of section 133(6) of the Act and did not bring on record anything contrary that the credit represent the income of the assessee. Thus, when the assessee by way of evidence

J S Exim Pvt Ltd, Chennai vs. DCIT Circle-13(1), New Delhi

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 854/DEL/2020[2013-14]Status: DisposedITAT Delhi04 Oct 2023AY 2013-14

Bench: Shri Chandra Mohan Garg & Shri Pradip Kumar Kedia

For Appellant: Mr. Amol Sinha, AdvFor Respondent: Mr. Waseem Arshad, CIT (DR)
Section 143(3)Section 68

respective returns of the lender companies. (c) that the AO has not considered it necessary to make any independent inquiry with lenders under Section 133(6)/131 of the Act. The AO has proceeded to formulate opinion on bona fides of such loans on the basis of common address, common

Rajkot Trading Corporation, Rajkot vs. The ITO Ward-3 (1) (2), Rajkot

The appeal of the assessee is allowed in above terms

ITA 55/RJT/2022[2011-12]Status: DisposedITAT Rajkot03 Oct 2023AY 2011-12

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumar(Through Web-Based Video Conferencing Platform) िनधा"रणवष"/Assessment Year: 2011-12 Rajkot Trading Corporation, Vs. The Income-Tax Officer, 13, Kailashpati Society, Ward 3(1)(2), Dhebar Road (South), Rajkot Rajkot -360002 Pan : Aacfr 5966 L अपीलाथ" अपीलाथ"/ (Appellant) अपीलाथ" अपीलाथ" "" "" यथ" "" "" यथ" यथ"/ (Respondent) यथ" Assessee By : Shri D.M. Rindani, Ar Revenue By : Shri Ashish Kumar Pandey, Sr. Dr सुनवाई क" तारीख/Date Of Hearing : 20.09.2023 घोषणा क" तारीख /Date Of Pronouncement: 03.10.2023 आदेश आदेश/O R D E R आदेश आदेश Per Annapurna Gupta: The Present Appeal Has Been Filed By The Assessee Against Order Of The Learned Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As "Cit(A)" For Short] Dated 15.12.2021 Passed Under Section 250 Of The Income Tax Act, 1961 [Hereinafter Referred To As "The Act" For Short] For The Assessment Year (Ay) 2011-12. 2. Ground No.1 Raised By The Assessee Challenges The Validity Of Assessment Framed In The Present Case Under Section 147 Of The Act. The Said Ground Reads As Under:-

For Appellant: Shri D.M. Rindani, ARFor Respondent: Shri Ashish Kumar Pandey, Sr. DR
Section 132Section 143(1)Section 143(3)Section 147Section 148Section 250

calling for information regarding the details of 5 Rajkot Trading Corporation Vs. ITO AY : 2011-12 payment made to the assessee under Section 133(6) of the Act only on 25.09.2018, i.e. six months after recording of the reasons by the Assessing Officer for reopening the case of the assessee

Shri Chandubhai Ramjibhai Kaqthiriya, Jasdan, Dist. Rajkot-364490 vs. The CIT(A), NFAC, Delhi

In the result, the appeal filed by the Assessee is allowed

ITA 168/RJT/2021[2017-18]Status: DisposedITAT Rajkot29 Sept 2023AY 2017-18

Bench: Us Is That The Ld. Cit(A) Erred In Upholding Addition Of Rs. 14,32,782/- Being 50 Percent Of Agricultural Income Treating As Unexplained Cash Credit U/S. 68 Of The Income Tax Act In The Absence Of Books Of Accounts.

Section 133(6)Section 143(3)Section 68

IN THE INCOME TAX APPELLATE TRIBUNAL RAJKOT BENCH, RAJKOT (Conducted Through Virtual Court) Before: Shri Waseem Ahmed, Accountant Member And

Shri Himanshu Lalit Ranka, Thane vs. Income Tax Officer Ward 2(1), Mumbai

In the result, both the appeals are allowed for statistical purpose

ITA 476/MUM/2023[2011-12]Status: DisposedITAT Mumbai27 Sept 2023AY 2011-12

Bench: Shri Kuldip Singh () & Ms. Padmavathy S. ()

Section 133(6)Section 142(1)Section 143(1)Section 144Section 147Section 148Section 69C

response from the assessee. Therefore the Assessing Officer proceeded to complete the assessment under section 144. The Assessing Officer issued notice under section 133(6) dated 29/01/2015 to the above mentioned parties with whom the assessee had undertaken the impugned transactions in order to verify the genuineness. However, no reply ... Tribunal. 4. The Ld.AR submitted that the Assessing Officer has made the addition merely based on the facts that the notices issued under section 133(6) were not responded. Accordingly, the Ld.AR prayed for deleting the addition. 5. The Ld.DR, on the other hand, submitted that

ITO Ward--2(1), Mumbai vs. Shri Himanshu Lalit Ranka, Thane

In the result, both the appeals are allowed for statistical purpose

ITA 1082/MUM/2023[2011-12]Status: DisposedITAT Mumbai27 Sept 2023AY 2011-12

Bench: Shri Kuldip Singh () & Ms. Padmavathy S. ()

Section 133(6)Section 142(1)Section 143(1)Section 144Section 147Section 148Section 69C

response from the assessee. Therefore the Assessing Officer proceeded to complete the assessment under section 144. The Assessing Officer issued notice under section 133(6) dated 29/01/2015 to the above mentioned parties with whom the assessee had undertaken the impugned transactions in order to verify the genuineness. However, no reply ... Tribunal. 4. The Ld.AR submitted that the Assessing Officer has made the addition merely based on the facts that the notices issued under section 133(6) were not responded. Accordingly, the Ld.AR prayed for deleting the addition. 5. The Ld.DR, on the other hand, submitted that