2015 (2) TMI 907

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....er Section 260A of the Income Tax Act, 1961 (the Act), challenges the order dated 8th August, 2012 passed by the Income Tax Appellate Tribunal (the Tribunal) for the Assessment Year 2006-07. 2. The Revenue has formulated the following question of law for our consideration: "Whether on the facts and in the circumstances of the case and in law, the Tribunal was justified in upholding the order....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....n it was declared that the sum of Rs. 35 lakhs would be offered to tax for A. Y. 2005-06. However, bill amounting to Rs. 14,97,970/- was raised on 31.3.2006 on M/s. Global Services Middle East for supply of provision time to time on Vesser "MV Pooja 1 & MV Stephanie. Copy of the Sale invoice for same made to M/s. Global Services Middle East for Rs. 14,97,970 is enclosed herewith. Also sum of Rs....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....A). In its order, the CIT(A) recorded that during the course of survey, no unaccounted invoices were impounded. Although there was unaccounted sale bills which were not recorded in the books of account on the date of survey, no document was impounded. However, later in its return filed with the Revenue, it declared turn over at Rs. 3.27 Crores, showing a net profit of Rs. 36.76 lakhs. The CIT(A) r....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....h unaccounted sales can rightly be taken as the amount which could be added to the Respondent-Assessee's income for the purpose of tax. 7. The grievance of the Revenue is that Section 69C of the Act is to be invoked and entire amount of undisclosed sales has to be brought to tax. We are unable to appreciate how Section 69C of the Act which speaks of unexplained expenditure is all at relevan....