2019 (7) TMI 1754

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.... The appeal is filed by the Revenue to challenge the Judgment of Income-tax Appellate Tribunal. Following question is presented for our consideration : "Whether on the facts and circumstances of this case and in law, the ITAT was correct in deleting the addition of Rs. 739.04 lacs stating that payment by the assessee of the amount of Rs. 739.04 lacs had not been established from the seize....

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.... 5-1-2007 to Panchanama dated 6-1-2007). The same was added on account of the payment being undisclosed, with the material found in search having established close business relationship between the assessee and PA. 104. We have heard the party before us, and perused the material on record. We firstly observe that the invoice for USD 1,600,000 (page 4 of Bundle 7/Ann. A supra), which is to....

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....delineating our reasons for considering the issue of TI as a valid ground for confirming the addition. At the same time, however, no TI has been issued for USD 16 lac. We have, vide para 22(b) of this order, found that no payment for USD 16 lac can be said to have been made; rather, the facts borne out by the record indicating to the contrary. The mention of the beneficiary account details and the....