2021 (12) TMI 27

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....nbsp; P. C. :- 1. The following substantial questions of law are proposed in this Appeal : (i) Whether on the facts and in the circumstances of the case and in law, the Hon'ble ITAT was justified in deleting the addition of Rs. 2,62,40,000/- made by the Assessing Officer u/s.69A of the Income Tax Act, 1961 solely relying on the submission made by the Assessee during the appellat....

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....143(2) of the said Act was issued followed by a fresh notice under Section 142(1) on 15/10/2009. Respondent responded to the said notices and attended from time to time the hearing and filed details. 3. A survey action under Section 133A was conducted on 11th / 12th May, 2007 in case of one M/s. Alliance Hotel and M/s. Hotel City Palace. During the course of survey, certain papers were found an....

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....added under Section 69A. 4. Respondent filed an Appeal before the Commissioner of Income Tax (Appeal) under Section 246A(1)(a). The said Appeal came to be allowed and the addition was deleted. Appellant impugned this order of CIT(A) before Income Tax Appellate Tribunal (ITAT) which confirmed the order of CIT(A) by an order dated 30/10/2015. The Appeal at hand is impugning this order passed by I....

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....tures and surmises without any evidence to dispute the explanation offered by the Assessee cannot be made. There should have been some money found with the Assessee. 6. There is no concrete evidence which has been brought on record by the Assessing Officer to establish that the entry 'Parvez Sir' in the impounded paper establishes the fact that it refers to Respondent. The Assessing Off....