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2013 (3) TMI 671 - AT - Income TaxAddition based on loose sheets found during the course of survey u/s. 133A - Held that:- Assessing Officer could make the addition on the basis of direct evidence on hand. If there is direct evidence on hand with the Assessing Officer for small period covering the assessment year, he could use the same for estimating the income of the whole year and as such the addition cannot be made only on presumption basis. In this case the material considered by the Assessing Officer for assessment is only loose sheets containing investments made by the partners of the firm. But the Assessing Officer not taken any pains to substantiate the addition based on the loose sheets. Being so, no addition can be made solely on the basis of a notebook or loose sheets which are dumb documents and the Assessing Officer is duty bound to bring on record corroborative material to show that the assessee has concealed the income. Being so, in our opinion, deletion of addition by the CIT(A) is justified
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