2008 (4) TMI 220

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....t was issued to the assessee, which was served on 31.8.1997. In response to the notice, the return of income for the block period 1.4.1987 to 24.6.1997 was filed on 29.5.1998 declaring therein a total undisclosed income of Rs.56,408/-. During the course of proceedings, it was found that the assessee has four daughters, namely, Nisha, Meenakshi, Sonia and Sunaina. The first three daughters were married between December 1995 to November, 1996 and the other one i.e., Sunaina was unmarried at the time of search. It was further found that the daughters of the assessee were not engaged in any business or any other work, which could generate any income, but they were maintaining bank accounts in which huge amounts were deposited from time to time.....

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.....  5,78,100/- on A/c of expenses on marriages of daughters (iv) Rs.20,43,756/- on A/c of Foreign Remittance received by assessee and family members (v) Rs. 7,00,000/- on A/c of investment and estimated profit during block period in the concern of Sujeet Sharma held to be property concern of assessee and (vi) Rs. 10,000/- on account of Household items vide order dated 28.3.2002 by holding that the daughters of the assessee are independent assessees and having declared the bank accounts, deposits in their name, have to be considered in their hands. 4. Feeling aggrieved against the said order, the Revenue filed an appeal before the Tribunal by raising the following grounds:- "1. That on the facts and circumstances of the case, the l....

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.... its order dated 2.3.2007 rejected all the grounds raised by the Revenue and dismissed the appeal of the Revenue. Still not satisfied with the order passed by the Income Tax Appellate Tribunal, Amritsar Bench, Amritsar,(for short the "Tribunal") the Revenue has filed the present appeal challenging the order of the Tribunal passed in IT(SS)A No.22(ASR)2002 dated 2.3.2007 for the block period 1.4.1987 to 21.6.1997, raising the following substantial questions of law:- (a) Whether in the facts and circumstances of the case the ITAT was right in law in confirming the order of the CIT(A) therein deleting the addition of Rs.70,33,000/- & 3,23,118/- by holding that daughters of the assessee are not Benamidars of the assessee ? (b) Whether in ....