2015 (7) TMI 571
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.... total income assessed was Rs. 7,88,08,743/-. On appeals being filed, the appellate authorities having interfered into the matter, this appeal by the revenue under section 260-A, of the Act. The only question raised in this appeal at the time of hearing was that the order passed by the appellate authorities in deleting an addition of Rs. 1,04,14,407/- on the ground of unaccounted transaction referred by the Assessing Officer, which was recorded in the seized documents BS-1 to BS-8, and by ignoring the same, reduction of the amount is said to be unsustainable. Shri Sanjay Lal, learned counsel for the appellant, referring to the order of the Assessing Officer and the manner in which the entries made in the seized documents, indicated in BS-....
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....y the appellant where there is a quick turnover, I consider it fair and reasonable if addition on account of unexplained investment for doing unrecorded turnover as found recorded in documents BS-1 to BS-8 is taken at Rs. 30,00,000/- as against the peak investment taken by the Assessing Officer at Rs. 4,56,80,360/-. Thus, appellant will get relief of Rs. 5,03,48,756/- [(Rs.1,45,60,000/- + Rs. 4,56,80,360/-) (Rs.68,91,604/- + Rs. 30,00,000/- )]. Further, after considering the same again in detail, the learned appellate tribunal has recorded the reasons in paragraph 39, as under:- 39. We have considered rival submissions and material available on record. The AO made the addition on this issue on the basis of loose papers found during course....
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....f the search. The submission of the ld. DR shows that even if some loose papers are recovered during course of the search, the computation of undisclosed income should be computed for whole of the block period. Such a submission itself would prove and support the findings of the fact recorded by ld. CIT(A) that there is no basis whatsoever in making huge addition against the assessee. The submission of ld. DR is already considered and decided against the revenue in the cases of M/s Sunita Jute Packagers, Radheshyam Gupta HUF and Kailash Agrawal (supra) by ITAT, Indore Bench. We therefore do not find any merit in the contention of the ld. DR. No material is also found during course of the search if assessee made any investment in making thos....