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2023 (2) TMI 709

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..... sturb the findings of the departmental authorities, inclined to uphold the addition. This ground is dismissed. Addition u/s 69C - unexplained investment - as in course of search and seizure operation, jewellery was found in the residential premises of the assessee - HELD THAT:- Undisputedly, jewellery was found in course of search and seizure operation conducted in the residential premises of the assessee. As could be seen from the observations of the departmental authorities, the assessee could not furnish any evidence or valid explanation to explain the source of investment in jewellery. Before us, no contrary evidence has been brought on record by the assessee for enabling me to disturb the finding of the departmental authorities - .....

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..... und that due to restriction imposed on account of COVID-19, the appeal could not be filed in time. Being satisfied with the reason shown, I am inclined to condone the delay and admit the appeal for adjudication on merits. 4. In ground no.1, assessee has challenged addition of Rs.1,48,000 under Section 69A of the Act. 5. Briefly, the facts are, the assessee is a resident individual. For the assessment year under dispute, the assessee filed his return of income on 11.08.2018 declaring income of Rs.3,49,110. 6. In course of search and seizure operation conducted on the assessee, cash amounting to Rs.1,48,000 was found. In course of assessment proceedings, the Assessing Officer called upon the assessee to explain the source of cash fou .....

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..... , jewellery worth Rs.6,70,020 was found in the residential premises of the assessee. 11. In course of assessment proceedings, when the Assessing Officer called upon the assessee to explain the source of jewellery, the assessee could not furnish any evidence. Therefore, the Assessing Officer treated the amount of Rs.6,79.020 as unexplained investment under Section 69C of the Act and added to the income of the assessee. The addition made was sustained by learned Commissioner (Appeals). 12. I have considered submissions of learned Departmental Representative and perused the material available on record. 13. Undisputedly, jewellery worth Rs.6,79,020 was found in course of search and seizure operation conducted in the residential premis .....

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