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TMI Blog2012 (12) TMI 1194X X X X Extracts X X X X X X X X Extracts X X X X ..... il Kureshi, J. - Assessee has filed this appeal against the judgment of the Income Tax Appellate Tribunal (for short 'the Tribunal') dated 17th September 2010 and further order in Miscellaneous Application passed by the Tribunal on 06th January 2012. The following questions have been presented for our consideration : "(i) Whether, in the facts and circumstances of the case, the Income ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in the facts and circumstances of the case, the Income Tax Appellate Tribunal was right in law in upholding the view of both the lower authority thereby charging interest under Section 139 of Rs. 7,97,324/- and interest under Section 215 of Rs. 54,07,935/- inspite of the facts that there was no mention thereof in the assessment order or that these are re assessment proceedings ? (v) Whether, in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... diction ? (viii) Whether, in the facts and circumstances of the case, the Income Tax Appellate Tribunal was right in law in confirming the order of CIT(A) that additions under section 68, 69 and 69A etc are to be made in the year of search if cannot be held that they are respect of A.Y. 1985-86 ?" 2. Though multiple questions have been framed, the centre issue pertains to additions sustained by ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 5% of the 'on money' receipts, in our opinion, no further examination at the end of the assessee is called for. It is, of course, true that the assessee had suggested addition of 10%. However, not accepting such suggestion would hardly give any rise to a question of law. We are also conscious that the decision of the Tribunal is called in question by the Revenue and the Tax Appeal is admit ..... X X X X Extracts X X X X X X X X Extracts X X X X
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