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2016 (8) TMI 1512 - AT - Income TaxPenalty levied u/s 271(1)(c) - addition made towards introduction of capital in partners account and towards unexplained credit - HELD THAT:- Assessee or his representative could not bring out any materials to establish that the additions are made and sustained due to possible interpretations of the Act or difference of opinion. It is purely a factual case where the assessee was not able to establish the genuiness of the credits in the assessee’s current account in the partnership firm where the assessee is the Managing Partner and other credits in his books of accounts which is elaborately discussed in the orders of the Revenue. These aspects of the case lead to the fact that the assessee has concealed his income. In such circumstances, we do not find it necessary to interfere with the order of CIT (Appeals). Accordingly we hereby confirm the order of the CIT (Appeals). Appeal of the assessee is dismissed.
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