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2013 (10) TMI 114 - HC - Income TaxIncome escaping assessment u/s 147 of the Income Tax Act – Undisclosed investment made by the Assessee - Held that:- There was no any credible material, which could relate to or connect to the investment of Rs.21 lacs by Reena Arora, which she had paid to D.N. Taneja - The entries in the diary of D.N. Taneja found during search and seizure, which he admitted were not of the amount of Rs.21 lacs paid by Smt. Reena Arora. The entries were with noting on the top (Praveen, Dilbagh) only indicated a schedule of payment. The name of Reena Arora did not appear in the diary. The A.O. while relying upon additions on the basis of the entries did not provide reasonable opportunity to the assessee. He did not allow cross-examination of D.N. Taneja by the assessee nor any bank statement or other records were found connecting these entries to Reena Arora - The investment made by Reena Arora and quantum was purely a guess work, which has been arrived at on surmises and conjectures without giving her an opportunity to be heard – Decided against the Revenue.
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