TMI Blog2017 (7) TMI 614X X X X Extracts X X X X X X X X Extracts X X X X ..... the Assessing Officer of having accepted that the Jewellery represented undisclosed income of the assessee's wife and daughter without establishing that they were capable of earning such income. He himself readily believes that the assessee had utilised this concealed income without having carried out any such enquiry in respect of the assessee. We therefore find it to be a simple case of mere su ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ppellant Mr.Sashi Tulsiyan with Mr.P.C.Tripathi, Advocate for the Respondent ORDER P. C. 1 The Assessing Officer passed an order under Section 158BC of the Income Tax Act, 1961 (hereinafter referred to as the Act ). The Commissioner of Income Tax passed an order under Section 263 of the Act against the said Order of the Assessing Officer passed under Section 158BC, whereby the Co ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ot give satisfactory explanation with regard to the seized jewellery to the extent of ₹ 26,67,547/. The benefit was given to the Assessee in respect of items of jewellery of which explanation was given by the Assessee. Total jewellery seized was valued more than ₹ 52 Lakhs. The learned counsel submits that even the travelling expenses of wife and daughter of the Assessee would come wit ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... explanation of the wife and daughter of the Assessee. The Tribunal in this regard has observed as under : ....We find the approach of the learned CIT to be rather contradictory in this respect. While he has accused the Assessing Officer of having accepted that the Jewellery represented undisclosed income of the assessee's wife and daughter without establishing that they were capable of ea ..... X X X X Extracts X X X X X X X X Extracts X X X X
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