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2022 (5) TMI 329 - AT - Income TaxAddition u/s 69A unexplained cash seized - As contended during the course of hearing that it is clear from a perusal of the assessee's income tax return, computation and balance sheet that the impugned sum represents the accumulated balances as well as cash sales realized in liquor business - HELD THAT:- We have given our thoughtful consideration to rival pleadings and find no reason to accept either party's foregoing submissions in entirety. This is for the reason that neither the assessee has been able to reconcile the liquor stock in trade with the sales/profits realized therefrom vis-à-vis the cash seized nor the department could altogether rebut the foregoing prima facie evidence to this effect. Faced with this situation, we deem it appropriate that a lump sum addition of Rs. 25 lakhs than that in issue of sum of Rs. 37.35 lakhs would be just and proper with a rider that the same shall not be treated as a precedent. The assessee gets relief of Rs. 12.35 lakhs in other terms. Necessary computation shall follow as per law.
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