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2003 (1) TMI 87 - CALCUTTA HIGH COURTUnexplained Money - From the order of the learned Tribunal at pages 35-36 of the paper book, it appears the assessee did not take this stand even in its letter dated March 6, 1989, before the Income-tax Officer that the assessee is not liable to explain the difference. It was for the first time such a stand was taken before the Tribunal. But then it is a finding of fact. Filing of the revised return by the partners immediately preceding the completion of the assessment has not been accepted as a reasonable explanation as enumerated under section 69A in respect of the previous year. As such in this case even if shown at the hands of the partners, the same has not been believed to explain the amount at the hands of the assessee under section 69A of the Act.
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