2014 (3) TMI 433

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....evenue is aggrieved by the Tribunal's order of 27.07.2012 whereby the CIT(A)'s orders deleting Rs. 41,55,000/- from the amount added by the Assessing Officer (AO) in the assessment during the course of his order was impugned by the Revenue. 2. It is urged that the Tribunal fell into error in overlooking very important and material circumstances such as the fact that the assessment order framed on....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....t was lastly urged that the nature of transactions revealed that even though the amounts were sourced through bank channels, neither any rationale was forthcoming nor the assessee came forward with genuine explanation why the Non-Resident Indians (NRIs) would advance huge amounts without seeking any interest or without having any personal relationship or with those of his immediate blood relatives....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.....2006 (paper book page 30). Mrs. Kalpana Dalal had received these amounts for giving to the assessee as follows:-  i) Rs. 15,30,000/- from assessee's own OD A/c No. 0619009301001637 with PNB (paper book page 5). ii) Rs. 10,36,000/- from Shri RS Chakraborty A/c No.6-0771 with Syndicate Bank (paper book page 7 back side). iii) Rs. 6800/- from Shri RS Chakraborty A/c No.61425 with Syndicate B....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....d documentary evidence. Therefore, we do not see any reason to interfere in the order of Ld. CIT(A).  XXXXXX XXXXXX XXXXXX'  6. It is evident that substantial amounts which were routed through the NRI's accounts emanated from the assessee's accounts or the overdraft account maintained by him. In other words, the essential character of the loan as disclosed by him was something verifiab....