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2018 (3) TMI 594 - HC - Income TaxAssessment u/s 153C - Search and seizure operation u/s 132 - Held that:- CIT(A) and the Tribunal premised their findings upon the admitted documents in the form of a compromise settlement in the course of which the relevant share of the parties’ rights and liabilities have been settled. The business, which had yielded such interest, had to be inevitably apportioned between the two brothers who had parted ways later. Income generated was during the period when both of them were together. Essentially, being factual, the findings are based upon a rationale which is both convincing and reasonable. The Court is of the opinion that there is no error of law with respect to the additions made. As far as the addition with respect to the unaccounted sum of ₹ 92,16,098/- goes, the Court notices that besides contesting that the assessee’s son was nick named “Golu”, there cannot be any denial that the documents seized clearly revealed the total expenditure that the assessee incurred in respect of both his children. Those were not traceable to the books of account or the returns that he had disclosed earlier. In these circumstances, the addition made was justified. - Decided in favour of the Revenue
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