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2014 (8) TMI 829 - AT - Income TaxUnexplained expenditure u/s 69C - Deletion of addition on the basis of loose sheets seized from premises – Contents of the documents not appreciated – Figures written were cash payments made to staff – Held that:- CIT(A) was rightly of the view that the AO cannot blow hot & cold at the same time whereby he cannot rely partly on the statement given by Shri Ashok Kumar Dokania. Either the statement is fully acceptable to the AO or not acceptable to him - He cannot be permitted to substitute figures of payment and the dates of payment without giving any cogent reasons - the assessee has not been given sufficient opportunity to cross-examine Shri Ashok Kumar Dokania during the course of assessment proceedings - the loose sheet is neither found nor seized from the premises of the assessee - CIT(A) has correctly taken cognizance of all the relevant facts and materials for deleting the addition on the basis of loose sheet found and seized from third party’s premises – Decided against Revenue.
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