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TMI Blog2024 (2) TMI 702X X X X Extracts X X X X X X X X Extracts X X X X ..... Ghildyal, learned counsel for the Union of India-Revenue and Sri R.R. Agrawal, learned Senior Advocate, assisted by Sri Nitin Kumar Kesharwani, learned counsel counsel for the assessee. 2. Present appeal has been filed under Section 260-A of the Income Tax Act, 1961 (hereinafter referred to as the Act) arising from the order or the Income Tax Appellate Tribunal, New Delhi dated 13.4.2023 passed i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ablish any suspicion, especially in view of the fact that the AO had given many opportunities to the assessee for providing the source and proof of old jewellery sold by the depositor or to provide wealth tax return of old jewellery? 2. Whether, in the facts and circumstances of the case and in law, the learned ITAT has erred in deleting the addition of Rs. 3,48,00,852/-made by the AO under Sect ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... any suspicion." 5. Thus it is seen that other than the suspicion raised by the assessing officer as to the genuineness of the transaction, no credible/ tangible material was brought on record by the assessing authority as may have led to any satisfaction or finding that the transaction was not genuine. The assessee not only disclosed the name of the jeweller's to whom the jewellery was sold by t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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