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2019 (2) TMI 1879 - AT - Income TaxAddition u/s 68 for alleged gifts - HELD THAT:- We find that the assessee is a member of same group and the alleged gift of ₹ 5,00,000/- has also been claimed to have been received by the company named Rajat Gems & Jewellers Pvt. Ltd. We are therefore inclined to sustain the addition u/s 68 of the Act for the alleged gifts as the assessee failed to explain its source and thus no interference is called for in the finding of Ld. CIT(A). Ground No.1 of the assessee’s appeal stands dismissed. Addition u/s 69C - unexplained expenses in marriage - HELD THAT:- On going through the submission made by Ld. Counsel for the assessee before the lower authorities as well as the loose papers impounded during the course of search we observe that and list of tentative invitees were 1589 persons but in the very same set of seized documents at item 15 of BS-1 there was invoice dated 18.2.2004 for printing of 1000 invitation card. Further the proof of payment to the caterers were also part of seized records. The addition made by Ld. A.O seems to be merely estimated because other than the list of invitees no other material evidence was unearthed by the search team which could prove that 1589 invitees attended the ceremony. Therefore in absence of no other evidence placed before us by the Revenue authorities and in the given facts and circumstances of the case it will not be justified to sustain the estimated addition u/s 69C of the Act merely on the basis of list of invitees. In the result the addition u/s 69C of the Act stands deleted. - Decided in favour of assessee.
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