TaxTMI 
TaxTMI 
2014 (9) TMI 1109
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.... Agrawal,Suyash Agrawal For the Respondent :- B.J. Agrawal,Ashok Kumar,D Awasthi,G Krishna,Rk Upadhyay,S Chopra JUDGEMENT 1. The present appeal is filed by the assessee against the impugned order dated 31.3.2004 passed by the Income Tax Appellate Tribunal, Allahabad in I.T.A. No.859(Alld.)/1999 for the Assessment Year 1993-94. 2. On 6.7.2009, a coordinate Bench has admitted this appeal on th....
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....rden shifted to the revenue to prove that the amount belong to the appellant, which the revenue failed to discharged." 3.The brief facts of the case are that the appellant was sanctioned a Petrol Pump and he started business on 25.9.1992 under the name and style of M/s Shukla Tail Apurti Kendra. It is the first year of the business of the assessee. The assessee has filed a return of loss income. ....
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...., he has taken a loan of Rs. 1,09,500/- from the five persons. But the A.O. was not satisfied, so he made the addition of Rs. 1,70,000/- in the hands of the assessee, which was confirmed not only by the first appellate authority, but also by the Tribunal. Being aggrieved, the assessee has filed the present appeal. 5. With this background, Sri Suyash Agarwal, learned counsel for the assessee submi....
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....and tuition and further he had taken the loan from five different persons, who were never examined by the A.O.. To support his arguments he relied upon the ratio laid down in the following cases:- (i). Deputy Commissioner of Income Tax Vs. Rohini Builders 2002 256 ITR 360 Guj; and (ii). Murlidhar Lahorimal Vs. Commissioner of Income Tax (2006) 280 ITR 512 (Guj) 6. On the other hand, Sri R. K.....