TMI Blog2011 (11) TMI 435X X X X Extracts X X X X X X X X Extracts X X X X ..... JJ. Ms. Savita Saxena for the Appellant. JUDGMENT G.S. Sandhawalia, J. - Affidavit of compliance regarding payment of costs as imposed vide order dated 28.7.2011 has been filed. 1. The present appeal is filed by the revenue under Section 260A of the Income Tax Act, 1961 (hereinafter referred to as "the Act") against order dated 30.6.2010 passed in ITA No.165/Chd/2010 for the assessment year 2006-07 whereby the appeal filed by the revenue against the order of the Commissioner of Income Tax (Appeals)-II, Ludhiana (for short "the CIT (A)" has been dismissed. The revenue has contended that the following substantial questions of law arise in the facts of the case:- "1. Whether on the facts and in law, the Hon'ble ITAT was l ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Singh Sidhu, Barjinder Singh Sidhu and Ravinder Singh Sidhu as a power of attorney holder on 20.12.2005 and received a sum of Rs. 22,50,000/-. It was further explained that deposit had been transferred in the Punjab National bank account from Saving Bank Account No.61524, which was in the name of Smt. Surjit Kaur. The Assessing Officer, accordingly, came to the conclusion that a sum of Rs. 35,61,066/-were deposited from undisclosed sources under Section 69A of the Act and treated the same as income of the assessee from undisclosed sources and accordingly held that notice under Section 271(1) (c) of the Act be issued separately. 3. That in appeal, the CIT(A) while examining various entries which were made in the two bank accounts came to t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n November, 2008. 4. That dissatisfied with the appeal being dismissed by the CIT (A), the appeal was filed before the Income Tax Appellate Tribunal, Chandigarh Bench 'A', Chandigarh (for short "the Tribunal") which came to the conclusion that the entire deposits in the bank accounts were explained as out of the money withdrawn from the joint saving account of assessee's father and mother of the Centurion Bank of Punjab and that transfer of funds by Sh. Ajit Singh Mangat from one joint account to another joint account cannot be treated as unexplained and the source of deposits have been duly explained. The revenue had failed to bring on record any evidence to show that the explanation of the assessee was incorrect. The explanation of the ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
