TMI Blog2019 (7) TMI 1097X X X X Extracts X X X X X X X X Extracts X X X X ..... , we are of the opinion that both the two questions as proposed by the Revenue cannot be termed as substantial questions of law involved in the present Tax Appeal. The Tribunal has concurred with the findings of fact recorded by the CIT (A). We do not find any perversity in the findings of fact recorded by the two Revenue authorities. - Appeal fails and is hereby dismissed - R/TAX APPEAL NO. 275 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... dition made on account of unexplained cash credit of ₹ 47,00,044/- under section 68 of the Income Tax Act, 1961 particularly when the identity, genuineness and creditworthiness of the unsecured loan lender parties were not proved by the assessee to he satisfaction of the Assessing Officer ? ( B) Whether Appellate Tribunal has erred in law an don facts in upholding th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... deposited cash of ₹ 3 lakhs on 19.10.2002, ₹ 5.5 lakhs on 22.11.2002 and 6.5 lakhs on 19.12.2002 and immediately thereafter cheques were given to the assessee on respective date. Further, this fact is also confirmed by the Shri M. Mehta recorded on oath under section 131 of the Act wherein he deposed that he has given 3 cheques to Shri Latif Ayub Kewar, partner M/s ke ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o the data. This, itself states that there is no doubt in genuineness of he expenditure but AO had made estimation of the undisclosed sources for such expenditure, We further find that on similar facts in the case of sister concern of the assessee M/s AyubBhecha Shipping and Allied Services Ayub Bahachan (sup) the ITAT had estimated the net profit @1.4%. Similarly, int he case of assessee, the I ..... X X X X Extracts X X X X X X X X Extracts X X X X
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