Pursuant to a search conducted at one of Virwani’s residences under Section 132 of Income Tax Act, the Assessing Officer passed assessment orders after making certain additions, by treating Virwani as a beneficial order of RAL.
Virwani’s challenge to these additions was dismissed by Commissioner of Income Tax (Appeals). He then moved the ITAT, where the additions were set aside holding that the Assessing Officer had not discharged the burden cast on him to prove that Virwani was a beneficial owner of RAL.
The Joint Commissioner for Income Tax (JCIT) at Bengaluru subsequently issued the assailed notice on the premise that Virwani owned RAL.
Thus, Virwani moved the High Court, where his appeal was dismissed by a single-judge, which led to the present appeal before the Division Bench.
Source: Barandbench
