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2022 (12) TMI 215 - AT - Income TaxAddition u/s 68/69 - undisclosed income - absence of source of purchase of the property - AO has made addition of 50% of the total value of the land as the appellant has not been able to explain the source of payment made in respect of purchase of land - HELD THAT:- As it appears from the detailed submissions made by the assessee supported by the sufficient documents, particularly, the cash book of the company, namely, Iscon Procon Pvt. Ltd. showing the source of investment made for such purchase of land situated at Ambapur, Gandhinagar, with another company, namely, Chehar Realty Pvt. Ltd., which establishes the fact of purchase of land by both the companies. Merely, because the assessee’s PAN number was mentioned as he was the Director of one of the company, the purchase cannot be said to be made by him when the purchase has been shown in the P&L account by the said company itself as well as part of the closing stock of the said company, namely, Iscon Procon Pvt. Ltd. In that view of the matter, the addition made by the Ld.AO has been rightly found to be not justified and deleted by the Ld.CIT (A), which, in our considered opinion is just and proper so as to warrant interference. In that view of the matter, the Revenue’s ground of the appeal is found to be devoid of any merit and thus dismissed. Revenue’s appeal is dismissed.
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