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2023 (4) TMI 57 - AT - Income TaxUndisclosed income - addition of value of unaccounted assets - addition adopting the figure of unaccounted assets offered by the assessee in the return of income filed under section 153A - DR supporting the order of AO stating that the figure of unaccounted assets /unaccounted capital/ unaccounted liability/ unaccounted sales have been given by the assessee itself and the AO has rightly adopted the highest figure as unaccounted income - CIT- A deleted the addition - HELD THAT:- In the instant case, we find that the AO has not raised any doubt on various figures shown for undisclosed and unaccounted assets/liabilities/capital/sales or the method of computation of undisclosed income. It is judicially well settled that when a document is found during the course of search, it has to be relied upon in entirety and there is no discretion available with the assessee or the Department to rely upon a part of the document favourable to it and plead for rejection of the other part which is not favourable to it, or in respect of which no supporting material is found. We, therefore, under the given facts and circumstances of the case and also the ratio laid down in Radhasoami Satsang [1991 (11) TMI 2 - SUPREME COURT] find no inconsistency in the finding of the ld. CIT(Appeals) deleting the addition made by the ld. Assessing Officer wrongly adopting the figure of unaccounted assets in place of the unaccounted capital offered by the assessee in the return of income filed under section 153A of the Act. Grounds No. 1 to 3 raised by the Revenue are dismissed.
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