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2016 (8) TMI 914 - AT - Income TaxAllowance of telescoping of debit entries (payments) against addition made on account of unexplained receipts (credits) - Held that:- CIT(A) has given a categorical finding that the debit side entry dated 09.03.2008 for ₹ 15 lacs is of similar narration being “cash amount transferred, Pradeep, Sanjay Goyal, cons by Ashishji.” Even name is mentioned i.e. Sanjay Goyal, Ashishji Goyal are also common. The said findings remain uncontroverted. In light of that, ld CIT(A) has rightly held that where the credit side cash entries have already been taxed then in that case the debit side cash entries have to be telescoped and he has accordingly given relief of ₹ 15 lacs. We accordingly donot see any infirmity in the order of ld CIT(A) in the said finding and the same is hereby confirmed. Hence, ground of Revenue is dismissed. Addition in the trading account - Held that:- CIT(A) has given a categorical finding of fact that both the transactions are of the same period and the determination of undisclosed income ₹ 81,73,000/- is based on P&L account and balance sheet of same period. It is not only the case that the profit of ₹ 81,73,000/- is reflected or detected by way of any independent source of any other undisclosed income. Therefore the income already detected and taxed in the same A.Y. should be given credit in as much as otherwise it will tantamount to double taxation. The said finding remains uncontroverted before us. Further, the Coordinate Bench in assessee’s appeal (supra) has questioned the very basis of the subject addition where it stated that without rejection of books of accounts, no such additions in the trading account only on the basis of retracted admission is justified. In light of above, we donot see a necessity to interfere with the findings of the ld CIT(A). Hence, ground of the Revenue is dismissed.
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