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2014 (1) TMI 345 - HC - Income TaxUnexplained cash credit - Held that:- As per section 68 - The reference to ‘any sum’ which is found to be ‘credited’ in the assessee’s book for any particular year can mean only one thing, i.e. the actual sum found in the books for the concerned previous year and which is unexplained - If the profits reported by the assessee are not accepted on the basis of the supporting accounts, the ITO can process such profits by estimation after rejecting the books - For separate heads of income such as profits, capital gains, etc., which would involve reporting of accounts maintained on an elaborate basis and also detailing expenditure etc., the Assessing Officer may have the discretion to reject accounts and arrive at the income on the basis of estimation - There cannot be any estimate for section 68, even if for the rest of the accounts, such an exercise is validly undertaken - This is for the simple reason that the expression ‘any sum’ refers to any specific amount and nothing more – Decided in favour of assessee.
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