TMI Blog2004 (12) TMI 298X X X X Extracts X X X X X X X X Extracts X X X X ..... 9. 2. The facts apropos to ground NO.1 are that search action was taken under s. 132 of the IT Act on 27th July, 1999 in respect of St. Soldier School and Sh. Anil Chopra group concerns covering business and residential premises of Sh. Anil Chopra, his family members and others, including residential premises situated at 331, SUS, Nagar, Jalandhar, and locker No. 37/2 with CUCB, Mithapur Road, J ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ducted and it was found that this locker was opened in March, 1998. Since this paper was bearing date of 15th Dec., 1997, the AO opined that the same was prepared prior to the opening of locker in March. 1999. Actually IVPs worth Rs. 27.73 lakhs (maturity value) were found from the locker. The AO observed that out of total IVPs worth Rs. 33.42 lakhs written on the said paper, only the IVPs worth ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ct-matter of taxation. Apart from that, the AO made addition of Rs. 5.69 lakhs on account of IVPs which in his opinion, the assessee might have sold or placed somewhere else. It is important to note that all the premises belonging to the assessee and the groups concerns were searched simultaneously and nothing has surfaced to show that the assessee, in fact, had made investment in IVPs to this ext ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ddition. 3. Second ground deals with the deletion of addition of Rs. 3,52,600 made on account of difference in FDRs. On the basis of same paper extracted above mentioning FDRs at Rs. 4.61 lakhs, only FDRs worth Rs. 1,08,400 lakhs were actually found in the name of the family members of assessee's daughter. The AO made addition for the balance amount of Rs. 3,52,600 (Rs. 4,16,000 1,08,400). The l ..... X X X X Extracts X X X X X X X X Extracts X X X X
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