Appeals for Multiple Assessment Years Dismissed/Partly Allowed by Tribunal

Former assessees' appeals for AY 2005-06 and 2006-07 were dismissed, AY 2009-10 was allowed, AY 2010-11 was partly allowed, and the latter assessee's sole appeal for AY 2010-11 was dismissed. The tribunal pronounced the order on 07/04/2021.

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Issues Involved:
- Appeals related to two taxpayers challenging additions made by lower authorities under the Income Tax Act, 1961 for various assessment years.

Analysis:

Former Assessee's Appeals - ITA 1068 to 1071/H/18:
- AY 2005-06 & 2006-07: The former assessee challenged the addition of unaccounted receipts and sundry creditors. The CIT(A) confirmed the addition of unaccounted receipts of Rs. 30 lakhs based on seized material and the assessee's modus operandi. The appellate tribunal accepted the CIT-DR's arguments, upholding the addition. The appeal for AY 2005-06 failed.
- AY 2009-10: The former assessee contested the addition of an unexplained liability of Rs. 12 lakhs, representing alleged promissory notes. The tribunal noted that the original promissory notes were seized, indicating incomplete loan transactions with third parties. As the Revenue failed to prove the payments from the assessee's side, the addition was directed to be deleted. The appeal for AY 2009-10 succeeded.
- AY 2010-11: The former assessee disputed the addition of borrowings and interest payments. The tribunal acknowledged the source of the loan and directed the Assessing Officer to restrict the addition to the interest payment component only. The assessee was granted telescoping benefit against previous unaccounted receipts and creditors. The appeal for AY 2010-11 was partly accepted.

Latter Assessee's Appeal - ITA 1072/H/18:
- AY 2010-11: The latter assessee challenged the addition of unexplained cash credits. The CIT(A) considered the bank deposits as unexplained credits due to lack of proof of past savings. The tribunal upheld the addition as the appellant failed to substantiate the claim. The appeal for AY 2010-11 failed.

In conclusion, former assessees' appeals for AY 2005-06 and 2006-07 were dismissed, AY 2009-10 was allowed, AY 2010-11 was partly allowed, and the latter assessee's sole appeal for AY 2010-11 was dismissed. The tribunal pronounced the order on 07/04/2021.

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