2009 (10) TMI 291

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.... court was delivered by 1. ADARSH KUMAR GOEL J.- This appeal has been preferred by the Revenue under section 260A of the Income-tax Act, 1961 (in short, "the Act") against the order dated February 4, 2009, passed by the Income-tax Appellate Tribunal, Delhi Bench "F", New Delhi, in I. T. A. No. 2993/Del/2008, for the assessment year 1993-94, proposing to raise the following substantial question ....

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.... claim of the assessee that the amount was received towards consideration for sale of material, was not accepted. Inference was drawn that the assessee siphoned off its unaccounted money by making M/s. Sahib Engineering Works a conduit pipe through which unaccounted money travelled and reached back to the assessee. Thus, addition was made to the declared income. Further additions were made by hold....

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.... 5. Learned counsel for the Revenue submits that the findings of the Tribunal that transaction for sale, for which amount is alleged to have been received from M/s Sahib Engineering Works, was genuine, is perverse. 6. This contention cannot be accepted. The Tribunal has recorded reasons taking into account, inter alia, the following circumstances: "A. The assessee sold steel to MIs Sahib E....

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....count of the assessee is from account of M/s. Sahib Engineering Works and money which came into the account of M/s Sahib Engineering Works came from accounts of M/s. Kotak, SRF and Times. Thus, the assessee has not only proved source of its credit but also proved source of source with corroborat ing overwhelming evidence." 7. The above reasons cannot be held to be non-existent. The matter is in....