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2014 (8) TMI 43 - ANDHRA PRADESH HIGH COURTBlock assessment u/s 158BA r.w 113 – Source of investment not properly explained - Addition u/s 69 - once an assessing authority notices an undisclosed income, an obligation arises for the assessee, to explain the source of the investment, which has yielded the income - If he fails to do so, Section 69 of the Act mandates that the entire amount shall be treated as income, itself - Notwithstanding the limitations in the context of hearing an appeal u/s 260A of the Act, it is left open for the assessee to explain the source of investment in respect of the undisclosed figures - Since that is not forthcoming, the only way out is to fall back upon the figures indicated by the revenue, the undisclosed income, as the income irrespective of the investment which is needed to yield that income or the absence of explanation of the source – assessee shall be under obligation to pay the tax on the undisclosed income of ₹ 50,00,000/- in the place of ₹ 32,00,000 – Decided partly in favour of Revenue.
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