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2022 (12) TMI 699 - HC - Income TaxAddition as value of ‘explained jewellery’ - quantum of unexplained income in the form of jewels in the hands of the respective appellants as above - undisclosed income in the form of unaccounted jewelers - HELD THAT:- A reading of the impugned orders of the Appellate Tribunal and the grounds of appeals raised by the respective appellants reveals that no substantial question arises for consideration for being answered in these appeals. The dispute pertains to only quantum of unexplained income in the form of jewels in the hands of the respective appellants as above. Though the learned Standing Counsel for the respondent submitted that the matter can be remitted back to the Assessing Officer for determination, the learned counsel for the appellants insisted for a order on merits of the respective appeals. We find no merits in these appeals as no substantial question of law arises for consideration. Appellate Tribunal is the ultimate fact finding authority. In appeal, we cannot come to a different conclusion on facts. These appeals are therefore liable to be dismissed. Impugned order is set aside and the case is remitted back to the AO, i.e. Deputy Commissioner of Income Tax, Central Circle-II, to pass a fresh order on merits in accordance with law in line with the direction of the Tribunal. Entire exercise shall be completed by the AO in the respective cases, within a period of three months from the date of receipt of a copy of this order.
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