TMI Blog2013 (10) TMI 1416X X X X Extracts X X X X X X X X Extracts X X X X ..... annot be made on surmises or on the basis of hypothetical assumption. In the present case, the finding of fact by the first appellate Authority was that there was no supporting evidence available other than the seized e-mail to arrive at a conclusion that the amount of ₹ 6,60,00,000/- was an additional undisclosed income. The Tribunal, in appeal, has accepted the view of the CIT(A), while ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 6,60,00,000/- made by the Assessing Officer towards the additional sale consideration received in respect of property at Taleigao ? (2) Whether on the facts and circumstances of the ease the order of the Tribunal is not perverse in deleting the addition of ₹ 6,60,00,000/-vvithout appreciating the evidences found during the search and the facts enumerated in the Assessment Order ? (3) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on the basis of an e-mail recovered during the course of search action at the premises of one Harish Jain. The CIT(A) came to the conclusion that during the course of the assessment proceedings, the details of the transaction relating to the property at Talcigao, had been furnished by the Assessee. No independent inquiry was made, nor was any corroborative evidence available for bringing the amoun ..... X X X X Extracts X X X X X X X X Extracts X X X X
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