2007 (7) TMI 281

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....rder dated My 19, 2006, passed by the Income-tax Appellate Tribunal, Delhi Bench "D", IT(SS)A. No.126 (Delhi) of 2000 relevant for the block period April 1, 1988, to April 21, 1998. During the course of search and seizure operations in the premises of the assessee, the Revenue recovered two sheets of paper marked as annexure A-72 in which certain items were jotted down in pencil such as dinner, gi....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....e preferred an appeal before the Commissioner of Income-tax (Appeals) who allowed the appeal and deleted the addition. It was held that there was nothing to show that the assessee had incurred the expenditure. 4. The Revenue then preferred an appeal before the Tribunal and since that was dismissed, the present appeal under section 260A of the Income-tax Act, 1961, has been preferred before us. ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ear that what is postulated in section 69C of the Act is that first of all the assessee must have incurred that expenditure and thereafter, if the explanation offered by the assessee about the source of such expenditure is not found satisfactory by the Assessing Officer, the amount may be added to his income. 7. In the present case, there is nothing to show that the expenditure was in fact incu....