2008 (3) TMI 4

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....d at the premises of the Assessee on 20^th July, 2000. Thereafter, notice under Section 158BC of the Act was issued to the Assessee and the Assessee filed the return for the block period on 22^nd June, 2000 declaring undisclosed income of Rs.47,93,000/-, details of which have been mentioned in the assessment order. 3.         During the course of assessment proceedings, the Assessing Officer brought to the notice of the Assessee that the undisclosed income of the family members of the group concerns had wrongly been disclosed by the Assessee in the return of undisclosed income. The Assessee filed his letter dated 11^th September, 2000 with revised particulars of undisclosed income to Rs.20,55,000/-....

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....pts or expenditures. 9.         In the present case, the Assessee has made the conditional offer in his statement which has been mentioned by the Assessing Officer in his assessment order and the same is reproduced as under:-"Actually, the slip 5 contains two types of entries-one from where the money had either come to me or I was supposed to receive it. The other type of entries where those where I was supposed to give money or had already given them. If you would see carefully, you will find that some entries have been ticked right". All such entries are those where money had to be given by me or had already been given away. The sources obviously was profits earned by me or money taken from other....

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....ion were.  I simply want to get over with this. However, I would reserve my right to contest and litigate if this surrender of 47 lacs is treated in any form other than application of my unaccounted profits from my business activities." 10.       Thus, the Assessee has surrendered Rs.47,00,000/- after due consideration of the documents seized. The subsequent retraction of the Assessee cannot be accepted and there is no basis for accepting the same. The Assessee had admitted that entries are in his own writing and has also admitted this fact that some of the transactions shown in the document were real. A document has to be accepted or rejected in toto. It cannot be said that a part of the document is....