2012 (8) TMI 738

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....e basis of incriminating documents recovered, notice was issued under Section 158BC of the Income Tax Act, 1961, hereinafter referred to as "the Act". The said proceedings for the block period 1.4.1986 to 12.12.1996 ended in Annexure-A. The same is not under challenge herein. 3. Subsequently, on 30.07.1998, the business premises of M/s.Puthur Drugs, Thrissur was searched and documents were seized, indicating investments made by various persons as partners of M/s.Hotel Luciya Drive Inn Restaurant, Chalakudy. The assessee's name also figured as a partner, who has invested money in the venture. Such investment revealed from the seized documents from M/s.Puthur Drugs, Thrissur was not disclosed by the assessee in the cash flow statement file....

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....fficer on the basis of documents recovered from another assessee's premises. The assessee also alleged that there was absolutely no cogent material available to assume a surviving partnership and in such circumstance, the addition of alleged amounts brought in by the assessee to the partnership on various dates could not at all be sustained. In such circumstance, the assessee contends that the order of the Tribunal is erroneous and is based on a perverse appreciation of facts. 6. We have given our anxious consideration to the arguments advanced on behalf of the assessee by the learned counsel Sri.Dale P.Kurian. Much reliance has been placed on the date of the partnership deed and the retirement deed to contend before us that the alleged ....