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2014 (2) TMI 1078 - HC - Income TaxBlock Assessment – Notice for undisclosed income for the block period u/s 158BC of the Act – Held that:- Both the authorities have expressed doubt regarding the sufficiency of the document as prima facie material and it is after verifying the statement of accounts, day book and ledger that they have formed an opinion that the certificate alone was not enough to mulct such a liability for payment of tax on the assessee - Since there is no perversity in the findings of the appellate authorities, thus, the contentions raised by the revenue cannot be taken as a substantial question of law. The appellate authority has considered all the documents produced and has clearly narrated the source of income for the purpose of the said investment - The view of the appellate authority had been confirmed by the Tribunal as well – The validity of the documents relied upon by the assessing officer had been considered in great detail and the first appellate authority had narrated the availability of evidence for arriving at the conclusions with reference to the undisclosed income alleged to have been made by the assessee - thus, there is no need to take a different opinion – no substantial question of law arises from the appeal – Decided against Revenue.
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