TMI Blog2021 (10) TMI 263X X X X Extracts X X X X X X X X Extracts X X X X ..... xplanation was not offered and if needed protective addition could have been made in the hands of assessee. Thirdly, Mr. Manoj Kumar Jain said to have received some amount credited in the bank account from sale of land, thereafter no efforts seems to have been made by the revenue authorities as appearing from records, to check the correctness of this statement. As per actual matrix of the case and loose ends of the enquiry conducted by the revenue authorities, assessee deserve to succeed as there is no direct material found by the revenue authorities against her to make the addition for undisclosed income - Decided in favour of assessee. - IT(SS)A No.01/Ind/2019 (Assessment Year: 2007-08) - - - Dated:- 23-8-2021 - HON BLE RAJPAL YADA ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... unlawful and unjustified and, therefore be deleted. 4. That on the facts and in the circumstances of the case and in law, the levy of interest u/s 234A 234B 234C are unlawful and hence be cancelled. 2. Brief facts as culled out from the records are that the assessee is an individual and partner in the firm, namely Agrawal Jewelers. Search u/s 132 of the Act was carried out on 13.11.2007. The assessee was also subjected to search. Notice u/s 153A of the Act was issued. In response return for A.Y. 2007-08 was filed and the same income was disclosed as was shown in the original return filed in the return submitted on 19.06.2008. Notice u/s 143(2) of the Act duly served upon the assessee. 3. Ld. AO while examining seized records ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... We find that nexus of the alleged addition is a bank account of Mr. Manoj Kumar Jain who is an employee of Agarwal Jewellers of which the assessee is a partner. In the bank account of Mr. Manoj Kumar Jain as reproduced in the assessment order on 24th August 2006, 31st August, 2006 and 1st September 2006 there are some credit entries of ₹ 27,000/-, ₹ 37.60 Rs, 6,500/- and also on 29.08.2006, 30.08.2006, 31.08.2006 02.09.2009, there are cash deposited of ₹ 23,000/- ₹ 20,000/-, ₹ 81,000/-, ₹ 1,30,000/- ₹ 10,000/-. On 2nd September 2006 a cheque of ₹ 2,86,561/- has been issued to assessee. When Mr. Manoj Kumar Jain was enquired by the revenue authorities about the source of cash deposit it ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
