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2018 (6) TMI 1386 - AT - Income TaxUndisclosed investment in equipment U/s 69 - e-mail communications dated 5.12.2011 and 11.12.2011 which has formed the basis of addition in the hands of the assessee company towards the cost of equipment - lack of enquiry - Held that:- We find that there is nothing on record in terms of any enquiry/ investigation which has been carried by the Assessing officer either during the assessment proceedings or even during the remand proceeding. The Assessing officer has not brought on record any credible verifiable evidence in terms of assessee company having incurred expenditure on purchase of equipments and grant of license over and above what has been stated in the books of accounts or the value of equipment and the cost of obtaining the license if so procured at the relevant point in time is higher than what has been stated in the books of accounts. Further, there is nothing on record which suggests these alleged investments have been made during the year under consideration. CIT(A) has also returned a finding that the channel has gone on air in the financial year 20010-11 pertaining to assessment year 2011- 12 and if any addition has to be made on account of unexplained investment, it has to be in A.Y. 2011-12 and not in the impugned assessment year. In light of the above discussions, we do not see any infirmity in the finding and order of the ld. CIT(A). - decided against revenue.
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