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2022 (9) TMI 1140 - AT - Income TaxAssessment u/s 153A - Unexplained income - income can be considered as unexplained either u/s. 68 or u/s. 69 - documents found during search “pertain /relate” to the assessee and did not “belong” to the assessee - HELD THAT:- We find no infirmity in the order of the CIT(Appeals), who specifically observed that in view of the specific satisfaction made in the assessment order to the effect that the documents “pertain/relate” to the assessee, it is evident that documents did not “belong to” the assessee, as was the mandate in view of various judicial precedents passed by the High Court/Tribunals in order to invoke provisions of 143(3) r.w.s. 153C of the Act prior to the amendment on 1st June 2015. CIT(Appeals), after taking into consideration the facts of the case and applicable judicial precedents has correctly applied the law to the instant facts before us, and we accordingly uphold the order of Ld. CIT(Appeals).
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