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of ITAT allowed the Revenue's appeal, set aside the CIT(A)'s order and upheld the assessing officer's addition of unaccounted receipts to the assessee's income arising from villa sales. The Tribunal found the assessee failed to discharge the primary onus to identify persons from whom unaccounted cash was received or to whom such sums were remitted, and did not furnish affidavits or supporting particulars despite specific calls. CIT(A) was held to have ignored material documentary evidence, failed to exercise co-terminus jurisdiction and merely followed a prior assessment without applying mind to the facts; consequently the AO's disallowance was sustained as valid addition to income.
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