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2021 (7) TMI 687 - AT - Income TaxCash found on the date of search - Since the assessee could not satisfactorily explain source, the AO treated the the cash amount as treated as undisclosed income of the assessee and brought to tax - HELD THAT:- The assessee has changed his stand on different levels of the proceedings. At the time of search and seizure operation, he stated that the cash belongs to his wife and at the time of assessment proceedings, he stated that the cash belongs to his son. Further, he stated that it belongs to SNR Nirmal India (P) Ltd. As per the above section, it is clear that the cash was found in the assessee’s residential premises, which was not explained to the satisfaction of the AO with corroborative evidence as well as before the CIT(A) also. We, therefore, relying on the judgments of CIT Vs. Durga Prasad More [1968 (8) TMI 17 - SUPREME COURT] and the case of Sumathi Dayal [1995 (3) TMI 3 - SUPREME COURT] we uphold the order of the CIT(A) and dismiss ground Nos. 1 & 2 raised by the assessee on this issue.
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