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2022 (2) TMI 1059 - AT - Income TaxUnexplained investment u/s.69 - Addition based on seized document - HELD THAT:- As seized document i.e. ledger account of Shri Manish Pinjani appearing in the books of account of M/s. R.S. Automobiles, Raipur, proprietary concern of the assessee evidencing receipt/repayment of loan of ₹ 1 lacs by Shri Manish Pinjani to the assessee was also seized in the course of the aforesaid search proceedings and form part of the seized document. Viz. LPS-13 . The said fact on a standalone basis can in no way establish to the hilt a nexus of the assessee with the contents of the incriminating document evidencing payment of ₹ 8,86,000/- towards purchase of the aforesaid property in question i.e. Plot No.47. We are of a strong conviction that as no nexus between the contents of the aforesaid incriminating document evidencing payment of ₹ 8,86,000/- has been established with the assessee before us, therefore, we are of the considered view that the addition of the same could not have been made in the hands of the assessee. We thus, in terms of our aforesaid observations vacate the addition made by the AO during the year under consideration. - Decided in favour of assessee.
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