2019 (2) TMI 728

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....Section 260A of the Income Tax Act, 1961 (the Act) challenges the order dated 9th December, 2015 passed by the Income Tax Appellate Tribunal (the Tribunal). This appeal relates to Assessment Year 2007-08. 2. The Revenue urges the following substantial question of law for our consideration : (i) Whether on the facts and in the circumstances of the case and in law, the Tribunal erred in deleting t....

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.... from undisclosed income. Thus, adding the same as undisclosed income under Section 69 of the Act in the assessment order dated 20th March, 2013 passed under Section 143(3) r/w Section 147 of the Act. 4. Being aggrieved, the respondent assessee filed an appeal to the Commissioner of Income Tax (Appeals) [CIT(A)]. By order dated 28th February, 2014 the CIT(A) on the factual examination of the evid....

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....ies have concurrently come to a finding of fact that loose papers does not have any signature of any person nor did it contain name of the respondent. We note that the loose document is a dumb document as it does not give any particulars of the persons involved in the alleged transaction. Thus, it is not open to the Assessing Officer to draw inferences from the document by interpreting the words "....