Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2017 (8) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2017 (8) TMI 1187 - AT - Income TaxUnexplained investment - addition on basis of seized document - several round of litigation - Held that:- since inception, viz. order passed by the A.O u/s 143(3) on 27.03.1998, the revenue had remained confused as to whether the amount (as is stated to have been decoded by the revenue) gathered from the ‘seized document’, viz. Page 128, represented a ‘loan given’ or a ‘loan taken’. We are of the considered view that now when it remains as a matter of fact that not only the impugned contents of the seized document, viz. Page 128 could be correlated by the revenue with any ‘seized material’, which could have justified drawing of adverse inferences in the hands of the assessee, therefore, it can safely be concluded that till date it remains an unsolved mystery for the revenue as to whether the same represented loans given or taken. - No additions - Decided in favour of assessee.
|