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2021 (2) TMI 325 - AT - Income TaxUndisclosed advances - Addition being made in respect of cash loan alleged to having being advanced in cash - addition solely on the basis of Annexure 'A' seized during search operation - estimating interest @ 8% on the alleged advances - HELD THAT:- We find force in the contentions so advanced by the ld AR that each of the entries reflect individual transactions with either date of advancement or repayment or tentative date of repayment and therefore, a generalized conclusion cannot be drawn basis review of just two entries where other entries applying same hypothesis will give a very incomprehensible conclusion. Given that there is no other corroborative evidence on record that the assessee has advanced such amount during the year under consideration, merely basis the reading and analysis of the seized document as a whole, it cannot be held that the assessee has entered into a fresh and different transaction with M/s Columbus Overseas LLP, other than the one which is duly recorded in its books of accounts. Thus, the addition of ₹ 25 lacs and consequent addition of interest of ₹ 2 lacs is hereby directed to be deleted. - Decided in favour of assessee.
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