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2020 (10) TMI 1016 - AT - Income TaxAddition u/s 69C of the Act on account of unexplained expenses incurred in foreign tour - HELD THAT:- A fair estimation has been made by him looking to the nature of expenditure which was incurred during foreign tour for both business and personal purpose. Thus no interference is called for in the finding of Ld. CIT(A) Ground No.1 of the Revenue’s appeal is dismissed. Addition u/s 69B on account of unexplained jewellery - HELD THAT:- CIT(A) has duly considered the permissible limits provided in the Central Board of Direct Taxes Circular No. 1916 dated 11.5.2014, ratios laid down by Hon’ble Courts and considering the number of family members, has rightly deleted the addition for unexplained jewellery made by the Ld. A.O u/s 69C of the Act. We thus find no reason to interfere in the finding of Ld. CIT(A) and confirm the same. Accordingly Ground No.2 raised by the Revenue stands dismissed. Addition for unexplained cash found at the assessee’s residence during the course of search - HELD THAT:- We observe that looking to the consistent substantial taxable income offered by the assessee for Assessment Year 2008-09 to 2013-14 and withdrawals made, we are of the view that the cash found at assessee’s residence is reasonable and explainable. We thus find no reason to interfere in the findings of Ld. CIT(A) and the same stands confirmed. Addition for unexplained opening balance of capital - HELD THAT:- Income shown in all these years has been offered to tax in the return of income and after subtracting the withdrawals for LIC premium, Income Tax, House loan interest and household expenses the resultant figure if cumulatively added and carry forward from Assessment Year 2008-09 onwards till the Assessment Year 2014- 15 the opening capital balance would have been ₹ 2,05,33,295/-. Assessee has taken the opening capital balance of ₹ 1,79,22,599/- which is less than the cumulative fund shown by the assessee in the chart. We thus in the given facts and circumstances of the case are of the view that Ld. CIT(A) has rightly appreciated the facts and deleted the addition as the assessee had duly explained the source of opening capital balance. Thus the finding of Ld. CIT(A) is confirmed and accordingly ground No.4 raised by the revenue stands dismissed.
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