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2022 (5) TMI 858 - HC - Income TaxUnexplained income - withdrawal shown in the seized documents belonging to the partners in their personal capacity or firm - whether withdrawals in the name of the partners of the firm represents the unaccounted income of the firm? - HELD THAT:- The principal contention of the writ applicant assessee before the Tribunal was that the amount of withdrawal reflected in the seized document represented the amount of the partners in their personal capacity. The Tribunal first looked into Section 292C of the Act and thereafter, noticed from the materials on record that the note in question was duly signed not only by all the partners of the firm, but also by three witnesses. The names of the partnership firm also figured in it. The Tribunal also took notice of the fact that the withdrawal of the money was from the firm. Thus, in view of the findings of fact recorded by the Tribunal as referred to above, no substantial question of law for the purpose of deciding this appeal under Section 260A.
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