TaxTMI 
TaxTMI 
2014 (3) TMI 326
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....essed under pressure in last date as time barred case. 3. That the ld. AO confirmed the credit worthiness of Dr Brijendra Singhal, who has given loan to the assessee and same advances not allowed to the assessee. 4. That under the facts and circumstances of the case, the ld. CIT(A), Income-tax, Alwar erred in confirming the addition made by the ld. AO. 5. That the assessee craves your indulgence to add, amend, or alter all or any grounds of appeal at the time, or before the hearing of the appeal.'' 2.1 Briefly stated, the facts of the case are that the original assessment in this case was completed on 24-02-1995 on total income of Rs. 12,69,068/-. The assessee went in appeal before the ld. CIT(A) who vide his order dated 21-03-1....
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....ness. The assessee has shown his income at Rs. 43,362/-. The total transaction of shares has been shown at Rs. 28,90,862/- and commission thereon has been shown @ 15%. The assessee furnished cash flow chart on the basis of bank entries. The assessee was asked to explain the source of deposit in the bank account with the help of evidence. The assessee did not maintain the books of account. It was stated that the assessee used to encash the refund orders through bank related to various persons and would charge commission @ 15%. He was further asked to furnish the details of parties to whom refund orders were encashed but instead of it, the assessee made a surrender of Rs. 7,39,288/-. It was contended that there was a peak credit for the quart....
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....proceedings on 22-12-2008. Dr Brijendra Singhal who is husband of sister of the assessee was produced before the AO for his personal examination. His statement was recorded on oath. In his statement, he admitted that he had given a loan of Rs. 8.00 lacs to Shri Raj Kumar Jain on various dates during the period between June, 1991 and Nov. 1991 in cash out of his bank account maintained in the PNB, Johri Bazar, Jaipur but no supporting evidence was produced. Accordingly, the AO did not rely on the statement of Dr Brijendra Singhal. It is noticed that the Tribunal has ordained that ''in the facts and circumstances of the case, the matter is restored to the file of the AO who will examine the issue de novo. The assessee is authorized to....
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.... and mental tension. It is stated that his sister Dr Bina Jain and bother-in-law Dr Brijendra Singhal used to come and visit Jaipur and Alwar in connection with Reception ceremony of their son to be held at Sisodia Garden, Jaipur on 27-12-2008. In proof thereof, the reception card was produced at the time of making statement. It is stated that in a marriage of daughter of his Sadu (Dr Brijendra Singhal) held on 21-12-2008, the marriage card was produced. Dr Brijendra Singhal has admitted this fact of giving loan in cash to his brother- in-law for business purposes and stated that he had withdrawn the same amount from his bank i.e. New Bank of India, Johri Bazar, Jaipur now merged into Punjab National Bank w.e.f. 3.-09-1993. The copy of this....