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TMI Blog2019 (1) TMI 153X X X X Extracts X X X X X X X X Extracts X X X X ..... NAM, J. This appeal, by the Revenue filed under Section 206-A of the Income Tax Act, 1961, is directed against the order passed by the Income Tax Appellate Tribunal 'A' Bench, Chennai (Tribunal) in I.T.(SS).A.No. 82/Mds/2007 dated 28.03.2008 for the Block Period 01.04.1989 to 25.11.1999. 2.The appeal has been admitted vide order dated 26.09.2008 on the following substantial question of law: "W ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... g Officer offering the entire deposits from the villagers of Rasipuram as income of the Assessee and that in the offer letter, it was clearly stated that the offer was made only to relieve the genuine depositors from the legal hassles of taxation and this was offered on the condition that the penalty and prosecution should not be initiated. The CIT(A) further noted that the Assessee made such a ca ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... orries. Thus, CIT(A) did not agree with the argument of the Assessee that the addition of Rs. 11,50,000/- was beyond the control of the Assessee. However, with regard to the other additions made by the Assessing Officer, the CIT(A) agreed with the stand taken by the Assessee that it was due to honest difference of opinion or due to inadvertence and in particular, with regard to the addition of Rs. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... was assessed only on the basis of disclosure made by the Assessee. Furthermore, the Tribunal noted that it is not on the basis of any evidence and investigation conducted by the Department and it was not unearthed by the act of the Department. Therefore, the Tribunal held that there was no justification to interfere with the order passed by the CIT(A). 7.On a perusal of the orders passed by the C ..... X X X X Extracts X X X X X X X X Extracts X X X X
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