TaxTMI 
TaxTMI 
2019 (10) TMI 1468
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.... appeals, common issue of unexplained household expenses is involved, and thus all the three appeals were heard together and dispose off by way of this consolidated order for the sake of convenience. 2. The grounds raised in all the three appeals are identical, except the amount of unexplained household expenses under dispute. Thus, for brevity, the grounds of the appeal raised in ITA No. 7119/Del/2017 for assessment year 2005-06 are only reproduced as under: 1. That the CIT(Appeals) erred on facts and in law, affirming the addition to the extent of Rs. 3,86,960/- on account of alleged unexplained household expenses incurred by the appellant. 1.1 That the CIT(Appeals) erred on facts and in law in not providing reasonable opportunity of....
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....nses of Rs. 4,94,022/- for assessment year 2005-06; Rs. 5,76,962 for assessment year 2008-09 and Rs. 5,79,592 for assessment year 2010-11 is appearing. For the assessment year 2010-11, the Assessing Officer projected total house-hold expenses at Rs. 8,87,755/-. The Assessing Officer found household withdrawal in capital account of the assessee at Rs. 1,02,932/- for assessment year 2005-06; Rs. 3,13,760/- for assessment year 2008-09 and Rs. 5,50,442/- for assessment year 2010-11, accordingly, after allowing the household withdrawals shown in capital account, the Assessing Officer made addition for unexplained household expenditure of Rs. 3,91,090/- for assessment year 2005-06; Rs. 2,63,202/- for assessment year 2008-09 and Rs. 3,37,313/- for....
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....stored to the file of the Assessing Officer for deciding afresh. 6. The learned DR, on the other hand, relied on the order of the Ld. CIT(A) and submitted that Ld. CIT(A) has already allowed relief corresponding to the source of expenditure explained by the assessee and, therefore, she opposed restoring the matter back to the Assessing Officer. 7. We have heard rival submissions and perused the relevant material on record. On perusal of the assessment orders, we find that the Assessing Officer has made addition of unexplained household expenditure based on the entries found recorded in the seized diary. The relevant finding of the Assessing Officer in assessment year 2005-06 is reproduced as under: "2.6.3 On perusal of the capital accou....
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....bank accounts of the assessee. 2.9 Subject to discussion above, as the amount of unexplained household expenses is more than the amount of unexplained credits in the various bank accounts of the assessee, the amount of unexplained household expenses of Rs. 3,91,090/-, the source of which has not been explained by the assessee, is treated as undisclosed income of the assessee. (Addition of Rs. 3,91,090/-)" 8. In second round of proceedings before the Ld. CIT(A), in assessment year 2005-06 the assessee filed copy of bank statements explaining the credit entries and other documents, the Ld. CIT(A) adjudicated the issue as under: "................................................................................... On a comparative consi....