TMI Blog2022 (12) TMI 673X X X X Extracts X X X X X X X X Extracts X X X X ..... f share holding of both the companies is also enclosed for the consideration and examination of CIT(A). CIT(A) neither disputed the said evidences filed on behalf of the assessee in support of its claim nor a reference made in the impugned order. The said details of investments filed before me and on perusal of the same at page 5 of the paper book, discloses that the assessee has share holding to an extent of Rs.2,15,500/- in Gupta Leasing Finance Ltd. during A.Y. 1999-2000 and Rs.60,000/- in Gupta Coalfields and Washeries Ltd. for A.Y. 2002-03. Therefore, the details investments of shares in two companies in A.Ys. 1999-2000 and 2002-03 were before the CIT(A) and the opening capital by way of a income for A.Ys. 2003-04 and 2004-05 w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... income from service charges and miscellaneous sources. The assessee initially declared total income of Rs.92,600/- u/s. 139 of the Act on 31-03-2007. The AO determined the total income of the assessee at Rs.4,59,186/- inter alia making addition on account of unexplained opening capital and unexplained investment in shares vide its order dated 10-12-2007. Thereafter, a search and seizure operation was conducted u/s. 132 of the Act in the business premises of Gupta Coal Group and residential premises of assessee on 29-07-2009. According to the AO, there was no seizure of cash and valuables from assessee and no disclosure was made u/s. 132(4) of the Act, but however, several items of books of accounts and incriminating documents were found and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... uring A.Ys. 1999-2000 and 2002-03 which is evident from the submissions of assessee before the CIT(A) which is reproduced in pages 4 and 5 of the impugned order. Further, I note that the assessee provided the details of such acquisition and which was examined by the Investigation Wing before the completion of proceedings u/s. 153A of the Act. Further, it is also observed copy of share holding of both the companies is also enclosed for the consideration and examination of CIT(A). The CIT(A) neither disputed the said evidences filed on behalf of the assessee in support of its claim nor a reference made in the impugned order. I note that the said details of investments filed before me and on perusal of the same at page 5 of the paper book, dis ..... X X X X Extracts X X X X X X X X Extracts X X X X
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