Sec. 153A  of Income Tax Act, 1961— Assessment— Assessee was a broker and Kunvarji Finance Private Limited is a client of the assessee. Inquiries revealed that the assessee M/s. Kunvarji Commodities Brokers Private Limited had done client code modifications for an unusually high number of times. According to the Assessing Officer, client code modifications have been made to hide the correct profit of a particular client. The Assessing Officer had made addition in the hands of the assessee on the basis of disclosure received that the assessee had received amount for providing client code modification.
 Court was of the view that the contention of the revenue that the addition with regard to client code modifications was subsumed in the addition made on account of non-disclosure made under section 132(4) of the Act, does not merit acceptance. The Court was of the view that both the questions proposed in the appeal stand covered by the findings recorded in the order dated 06.10.2015 passed in Tax appeal. Under the circumstances, no case wass made out for recall of the order dated 02.11.2015 made in the captioned appeal.
The application, therefore, fails and was, accordingly, rejected. --- Pr. CIT vs. KUNVARJI COMMODITIES BROKERS PVT. LTD. [2020] 23 ITCD Online 7 (GUJ)