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2014 (2) TMI 507 - ITAT AHMEDABADUndisclosed sales and purchase - Search made u/s 132 of the Act – Incriminating documents found during search – Held that:- The CIT(A) was reasonable as also justified in granting the part relief to the assessee - The reasons assigned is evident that it is justifiable on the part of CIT(A) - This is not a case where the addition was made in a regular or normal course of assessment proceedings - But where on account of search or surveys certain documents were unearthed and on that basis the addition was made - The amount which was already declared by the assessee was considered and due relief was given, but for rest of the amount in the absence of satisfactory explanation the addition was made - In the absence of any evidence on merits from the side of the assessee, the order of the CIT(A) upheld – Decided against Assessee. Unaccounted transactions as undisclosed sales and purchase - Search made u/s 132 of the Act – Incriminating documents found during search – Held that:- The amount as reflected in AS-21 of Rs.4,69,000/- and an amount as appeared at AS-24 of Rs.42,000/- did not belong to the assessee - the entries on that paper did not relate to the assessee rather no name of the assessee had appeared at any place on this document marked as AS-21 which was not recovered from the assessee but from the premises - the treasury receipt marked as AS-24 did not belong to the assessee but it was related to some other party, namely, M/s. Royal Enterprises - the assessee's contention has some force, thus, deserves relief only in respect of these two additions - For rest of the documents, the same have been proved to be connected to the assessee, hence, no interference is required in respect of those additions – Decided aprtly in favour of Assessee.
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