2006 (7) TMI 126

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....ncome-tax Appellate Tribunal in I.T.A. No. 24 (Del)/2001. The impugned order has been passed in respect of the block period April 1,1986 to March 31, 1997. It appears that the assessee had received an amount of Rs. 3 lakhs in cash from M/s. D.S. Imports. According to the Assessing Officer, the amount represented undisclosed income in the hands of the assessee while according to the assessee it ....

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..... In so far as the quantum issue is concerned, the Commissioner of Income-tax (Appeals) in a separate order dated September 6, 2000, came to the conclusion (in paragraph 7.2 of the said order) that the addition under section 158BC of the Act could not be sustained and that the Assessing Officer could at best have taken action under section 147 of the Act. Accordingly, the addition of Rs. 3 lakh....

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....he same time seek to initiate proceedings against the assessee for violation of the provisions of section 269SS of the Act which deals with cash deposits or loans in excess of Rs. 20,000. The Revenue, having taken the stand that the income was undisclosed income in the hands of the assessee, it could not resort to proceedings under section 269SS read with section 271D of the Act, as held by the....