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2021 (4) TMI 7 - AT - Income TaxAddition u/s 68 - addition on the basis of receipts in the ledgerised cash sheets as per annexure of seized material found during the course of search - HELD THAT:- On perusal of the entire gamut of seized material, we find that there is a master cash book which is marked AA-6 of R-2 which is based on all other documents seized. Based on the said master cash book, surrender was made with regard to all the enclosed set of books which was accepted by the department. In that case we do not find any reason or justification to make separate addition with regard to the same account incorporated in the ledger account and the entries of ledger account arising out of the master cash book. This precise explanation was also given before the AO which has not been adverted to by the Ld. AO. CIT(A) has given a categorical finding as incorporated above after examining each and every entry appearing in the said seized documents which has also been shown to us during the course of hearing from the said seized documents. On independent examination of the documents, we agree with the findings of the CIT (A) that the addition made by the AO has led to double addition and the same nature of transaction have been recorded in the master cash book and ledger account of summary sheet which is nothing but summary of all the transactions recorded in other seized documents. No material has been brought on record to controvert the findings of the Ld. CIT (A) and, therefore, the order of the Ld. CIT(A) deleting the addition has confirmed and the grounds raised by the revenue are dismissed. Since we have already held that exactly same issue is involved in other two years and the same set of facts and findings are permeating therein also apparently our findings will apply in the other two year also.
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