2017 (12) TMI 366

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..... This appeal is directed against the order passed by the Income Tax Appellate Tribunal, Madras 'A' Bench in ITA.No.878/Mds/2016 dated 26.10.2016. 2. The above appeal has been filed raising the following substantial questions of law : "i. Whether the Appellate Tribunal is justified in confirming the finding of the Commissioner of Income Tax (Appeals) that there is no on-mone....

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.... 132 of the said Act in the assessee's case on 14.12.2012, during which, it was found that the assessee purchased M/s.PSP Steels (P) Ltd. for a consideration of Rs. 22 Crores. The assessee was asked to explain the source of payment of Rs. 22 Crores. The assessee explained that his company M/s.Sastha Steels (P) Ltd. purchased M/s.PSP Steels (P) Ltd. The purchase included land, building and mach....

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....ssing Officer was of the opinion that this statement is a retraction of the earlier statement made by the assessee without corroborative evidence and given after a considerable lapse of time, confirmed the addition and concluded the assessment by passing the order dated 13.8.2014. 6. The assessee carried the matter on appeal to the Commissioner of Income Tax (Appeals). Before the Commissioner o....

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....st the order passed by the Commissioner of Income Tax (Appeals), the Revenue filed an appeal before the Tribunal. Ultimately, the Tribunal found that the assessee purchased M/s.PSP Steels (P) Ltd. for Rs. 22 Crores, out of which, a sum of Rs. 19 Crores was paid through banking channels, which was not disputed by the Department. Thus, this fact having not been disputed and controverted and the date....