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2020 (11) TMI 898 - AT - Income TaxAddition u/s 69A - assessee offered a sum of ₹ 3,00,000 as ‘Miscellaneous Receipt’ in her revised computation of income - Authorities have made and confirmed the instant addition on the ground that this receipt of ₹ 3,00,000 was different from the deposit of ₹ 3,00,000 in the bank account - HELD THAT:- We are unable to appreciate the view point of the authorities below on the ground that once the assessee offered a sum of ₹ 3,00,000 on receipt of the amount, there could have been no occasion of making another similar addition on spending/investing the said amount. If a person earns ₹ 100 from undisclosed sources and thereafter offers it for taxation, its later utilization, and that too, through undisclosed transactions, would not invite any further addition. AO cannot make one addition at the time of earning the undisclosed income and another similar addition at the time of spending the same. Here is a case in which the assessee offered ₹ 3,00,000 as ‘Miscellaneous Receipt’, which has been duly taxed also. The utilization of such amount of ₹ 3,00,000 by the assessee by means of deposit in the bank account, cannot, in our opinion, call for any addition. We, therefore, order to delete the addition. - Decided in favour of assessee.
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