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The Assessing Officer (AO) made additions u/ss 69C and 68 for undisclosed credit card expenditures in foreign currencies based on material found during a survey. The assessee possessed various international credit cards belonging to friends and relatives, enabling utilization without their presence. Despite requests, the assessee failed to provide details or explanations. The AO reopened the assessment and issued a notice u/s 143(2) to investigate further. In the absence of any material or evidence from the assessee or card owners, the AO treated the funds as unexplained income u/ss 68 and 69C. The CIT(A) upheld the additions, distinguishing the case from cited decisions. Regarding the protective addition for unexplained money received through Ananda Heritage Hotels P. Ltd., the ITAT observed that the investment was made through Wilton Investment Ltd., and the substantive addition was made in Ananda Heritage Hotels P. Ltd.'s hands. The CIT(A) deleted the protective addition in the assessee's hands, which the ITAT upheld, dismissing the Revenue's appeal.
The Assessing Officer (AO) made additions u/ss 69C and 68 for undisclosed credit card expenditures in foreign currencies based on material found during a survey. The assessee possessed various international credit cards belonging to friends and relatives, enabling utilization without their presence. Despite requests, the assessee failed to provide details or explanations. The AO reopened the assessment and issued a notice u/s 143(2) to investigate further. In the absence of any material or evidence from the assessee or card owners, the AO treated the funds as unexplained income u/ss 68 and 69C. The CIT(A) upheld the additions, distinguishing the case from cited decisions. Regarding the protective addition for unexplained money received through Ananda Heritage Hotels P. Ltd., the ITAT observed that the investment was made through Wilton Investment Ltd., and the substantive addition was made in Ananda Heritage Hotels P. Ltd.'s hands. The CIT(A) deleted the protective addition in the assessee's hands, which the ITAT upheld, dismissing the Revenue's appeal.
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