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2012 (10) TMI 95

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....nts: M/s B. Poddar, M. Choudhary, D. Poddar, P.Poddar & Amrita Sinha Heard learned counsel for the parties. The appellant is aggrieved against the finding recorded by the C.I.T.(Appeals) in its order dated 20.4.2010 and by the Income Tax Appellate Tribunal, Ranchi Circuit Bench, Ranchi in order dated 14.7.2011. As per the brief facts of the case during the course of search on 18.7.2006 so....

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....However, the C.I.T(Appeals) did not found anything adverse regarding the income declared by the assessee in his return. The finding recorded by the A.O. has been considered by the C.I.T.,(Appeals) in para 7(iii) and 7(iv). According to C.I.T.,(Appeal), the A.O. has not given any reason for not accepting the explanation furnished by the assessee in respect of the transactions relating to the seized....

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....rded by the C.I.T, Appeal has been upheld by the Tribunal. Learned counsel for the appellant vehemently submitted that when the document is seized, it is required to be considered as a whole and it cannot be rejected in part only. It is submitted that in this case the assessee could not explain the reason for mentioning the name of one Mithlesh Singh and, therefore, it may be presumed that amou....