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2012 (7) TMI 719 - AT - Income TaxAddition being 20% of contract payments u/s 40A(3)- On the basis of material found during the survey assessee surrendered undisclosed income of Rs. 3 crores and the impounded documents revealed cash payments exceeding Rs. 20,000/- each - Held that:- It can very well be seen that the payments made in single transaction to a particular person has been divided into multiple entries while recording the same in regular books of accounts and as the registers were found during the course of survey, these are primary evidence and are more reliable. The submissions made subsequently are only afterthoughts to give them the genuine colour - AO has considered all the documents seized during the course of survey and also the explanation of the assessee company on various entries submitted during the course of assessment - no evidence has been placed in support of this assertion, as affidavits of six persons were obviously filed at the instance of the assessee to serve his interest and such self-serving affidavits hardly achieve any purpose, especially when no cogent material has been placed before the lower authorities and even before us in support of contents of the affidavits - There is nothing to suggest that the relevant material has not been considered by the lower authorities - against assessee.
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