TaxTMI 
TaxTMI 
2016 (6) TMI 520
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....eing disposed of by this common order for the sake of convenience. 2. The grounds raised in ITA No. 1405/Del/2009 (AY 2003-04) read as under:- i) On the facts and circumstances of the case and in law, the CIT(A) has erred in deleting the addition of Rs. 91 lacs on account of income from undisclosed sources. ii) On the facts and circumstances of the case and in law, the CIT(A) has erred in directing to amend the return after verification filed by the assessee for AY 2006-07 when the issue did not arise out of appeal for AY 2003-04. iii) On the facts and circumstances of the case and in law, the CIT(A) has erred in directing that income of AY 2006-07 be modified when the ground of appeal for present assessment year have been duly ....
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....gs and filed the details. Thereafter, the AO assessed the total income at Rs. 94,54,270/- by making additions vide order dated 31.12.2007 passed u/s. 143(3) read with section 153A of the I.T. Act. 4. Aggrieved by the aforesaid order of the Assessing Officer dated 31.12.2007, assessee filed an appeal before the Ld. First Appellate Authority, who vide impugned Order dated 23.1.2009 has partly allowed the appeal of the Assessee. 5. Aggrieved with the aforesaid finding of the Ld. CIT(A), Revenue is in appeal before the Tribunal. 6. Apropos Ground No. 1 relating to deletion of addition of Rs. 91 lacs on account of income from undisclosed sources is concerned. 6.1 On this issue, Ld. DR relied upon the order of the AO and reiterated th....
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.... 7.1 Since we have already upheld the order of the Ld. CIT(A) on the ground no. 1 i.e. deletion of addition of Rs. 91 lacs, hence, the issue involved in ground no. 2 and 3 have become academic, therefore, we are not adjudicating the same. In the result, this Appeal filed by the Revenue stands dismissed. ITA NO. 1407/DEL/2009 (AY 2006-07) 8. The grounds raised in ITA No. 1407/Del/2009 (AY 2006-07) read as under:- i) On the facts and circumstances of the case and in law, the CIT(A) has erred in deleting the addition of Rs. 60 lacs on account of income from undisclosed sources. ii) On the facts and circumstances of the case and in law, the CIT(A) has erred in deleting the addition of Rs. 82.50 lacs on account of income from undi....
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....ings and filed the details. Thereafter, the AO assessed the total income at Rs. 1,68,66,260/- by making various additions vide order dated 31.12.2007 passed u/s. 143(3) read with section 153A of the I.T. Act. 10. Aggrieved by the aforesaid order of the Assessing Officer dated 31.12.2007, assessee filed an appeal before the Ld. First Appellate Authority, who vide impugned Order dated 23.1.2009 has allowed the appeal of the Assessee. 11. Aggrieved with the aforesaid finding of the Ld. CIT(A), Revenue is in appeal before the Tribunal. 12. Apropos Ground No. 1 relating to deletion of addition of Rs. 60 lacs on account of income from undisclosed sources is concerned. 12.1 On this issue, Ld. DR relied upon the order of the AO and reit....
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.... page 8 could have been taxed as income from undisclosed sources is if a reasonable view could be taken on such connotation of the entry from the available facts. The entries simply stated is "paid to Bedhi 10 + 50, Dis to KB regd. - ½ - ½". There are no dates available to indicate the timing of the entry. Neither is there any evidence to indicate as to whether the entries pertain to receipt or expenditure. Finally there is no correlation between the entries in the reverse of page 8 of A- 7 and the entries on the front side of the said page. as also the assessee's projects from A.Y. 03-04 to 06-07. Therefore, the ld. CIT(A) has rightly held that the entries on the reverse side of page 8 of A-7 could not have been deciphered as....