TaxTMI 
TaxTMI 
2016 (3) TMI 113
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.... "1. That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in confirming the action of Ld. AO in making disallowance of Rs. 6,13,725/- claimed by the assessee, more so when such disallowance could not have been made in the proceedings u/s 153A of the Act. 2. That in any case and in any view of the matter, action of Ld. CIT(A) in not deleting the disallowance of Rs. 6,13,725/- made by Ld. AO is bad in law and against the facts and circumstances of the case. 3. That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in not deleting the addition of Rs. 3,32,04,460/- fully as made by Ld.AO on account of alleged unexplained ....
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....inating material has been found as a result of search. 8. That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in not reversing the action of Ld. AO in charging interest 234B of the Income Tax Act, 1961. 9. That the appellant craves the leave to add, modify, amend or delete any of the grounds of appeal at the time of hearing and all the above grounds are without prejudice to each other. Revenue's Grounds of appeal ITA no. 5369/D/13 1. On the facts and in the circumstances of the case, the CIT (A) has erred in restricting the addition of Rs. 3,32,04,460/- made by the AO on account of unexplained investment to Rs. 33,20,446/- and directing the AO to delete 90% of....
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.... must have spent money which could be unaccounted for. 4. Aggrieved by the order of the ld.CIT(A), the assessee is in appeal before us now. 5. The ld. AR in respect of Ground Nos.1 and 2 of the assessee's appeal submitted that, as the issue has been set aside by the ld.CIT(A) to the ld. AO for verification with certain directions, the same are not be pressed before us. Accordingly, we are not inclined to adjudicate these grounds. 6. We shall first take up the appeal filed by the assessee in; ITA No.5296/Del/2013. 6.1. Ground No.3 of the assessee's appeal relates to the addition made by the AO in respect of unexplained investments in jewellery amounting to Rs. 3,32,04,460/-. 6.2. The ld. AR submitted that the addition has b....
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....it of weight of jewellery disclosed in the return, as it is a well known fact that Indian ladies keep changing the design of jewellery from time to time. Simply because the assessee could not lead any evidence for conversion or remaking of the jewellery, the possession of which was otherwise accepted, it could not be said that holding of the jewellery to that extent could not be accepted. 8.2. It is further submitted that the assessee her husband and their daughter-in-law have been possessing jewellary in the preceding and subsequent years and have been always assessed to wealth tax. The fact remains that the jewellary found was much less than the jewellary disclosed in the wealth tax returns accepted by the Department and hence no addit....