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2016 (11) TMI 953 - AT - Income TaxUnexplained bank transactions - Held that:- The assessees could not explain as to how the amount of ₹ 5 lakhs withdrawn from the common bank account was utilized. Looking at the entire facts and circumstances, the issues were to be decided on surrounding circumstances and human conduct. The burden to prove the cash entries is on the assessee since the requisite burden has not been discharged by the assessee in this behalf. In view thereof, the orders of the ld. CIT(A) on this issue are upheld. Thus, assessees’ appeals are dismissed. Apropos Somabhai Ambaalal Prajapati for AY 2005-06, it has not been disputed that the corresponding purchases are not shown in the seized record. Consequently they remained unaccounted. In view thereof, ld. CIT(A) has rightly appreciated the issue and held the entire unaccounted sales to be unaccounted income as the purchases expenditure are not found recorded. Apropos Pankaj Somabhai Prajapati, ld. CIT(A) in his order has given proper calculation and established that the source of loan of ₹ 18,81,429/- remained unexplained. Assessee, except making general comments, could not objectively prove that the assessee’s prima facie onus in respect of this loan was satisfactorily discharged. Assessee appeal dismissed
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