2012 (5) TMI 658

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.... The present appeal had come up for hearing on 5th April, 2011 and has been repeatedly adjourned. It appears that adjournments were taken to enable the Revenue to place on record the seized documents on which the Assessing Officer had relied. The seized documents have not been placed on record and the statement of Navneet Jhanb, who had brokered the deal between the respondent-assessee and Indo-A....

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....,72,800/-, the Assessing Officer had made two other additions of Rs. 12,77,200/- on account of unaccounted cash and Rs. 10,00,000/- on account of interest on Rs. 12,77,200/-. These two additions were also based upon the same documents.  3. The CIT (Appeals) deleted the said additions and had summarized the factual position after examining the material/evidence, as follows:-  ?Thus,....

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....ive can be made out from the documents seized.  7. The impugned document is neither signed by the assessee (i.e. purchaser) nor by the seller. The assessment order was framed u/s 147 and primary burden of proof was upon AO in view of decision of Hon?ble Delhi High Court in the case of CIT Vs. Pradeep Gupta. But AO failed to bring any material on record to corroborate his allegations about ....