2013 (7) TMI 116

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....lenging the judgment of the Income Tax Appellate Tribunal (hereinafter referred to as 'the Tribunal') dated June 15, 2012, present Tax Appeal is preferred under Section 260-A of the Income Tax Act, 1961 (hereinafter referred to as 'the Act'), proposing following substantial questions of law :- "A. Whether in the facts and circumstances of the case and in law the Hon'ble ITAT is justif....

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.... before the CIT (Appeals), it deleted the entire amount by elaborate discussion of the issue. It was during the course of the search that such jewellery has been found at the residence of the assessee. The statements of different family members were recorded. The confirmation/ affidavit of the father, mother, wife of the assessee claiming jewellery were also recorded. In such background, the CIT (....

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....iately by both the authorities, no entertainment is necessary. 4. As far as questions (B) and (C) are concerned, the same are pursuant to deletion of Rs. 91,17,075/- made by the Assessing Officer on account of interest calculated on the cash loans. During the course of search, certain documents and loose papers were seized and the assessee had made disclosure of huge amount of cash loans given ....

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....ulate the interest on such cash loans and make addition to that extent. Accordingly the addition made at Rs. 91,17,075/- made will be modified by him. With this remarks this ground of appeal is partly allowed." 5. When the Revenue challenged the same before the Tribunal, it on discussion of the findings of the CIT (Appeals) deleted entire sum and interest. This issue again is based on the factu....