2023 (8) TMI 593

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....ncome Tax Act, 1961, challenging the orders passed by the Income Tax Appellate Tribunal Division Bench Chandigarh in Income Tax Appeal No. 1152/Chd./2012, dt. 06.06.2016 and Income Tax Appeal No. 1153/Chd./2013, dt. 06.06.2016. 2) Income Tax Appeal No. 64 of 2016, relates to the assessment year 2007-08 and Income Tax Appeal No. 65 of 2016, relates to the assessment year 2008-09. 3) The assessee had previously filed a return of income for the assessment year 2008 declaring total income of Rs. 1,58,02,980/-. 4) The admitted facts are that there were search and seizure operations under Section 132 of the Income Tax Act, 1961 on Dhir Group of which appellant is a member on 10.8.2006 by the Investigation wing of the Income Tax Departmen....

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....in favour of the assessee by directing the Assessing Officer to determine the peak credit for the bank accounts of the assessee. 12) This was challenged by both the assessee as well as the Department before the Income Tax Appellate Tribunal (ITAT). 13) Before the ITAT, the assessee contended that as there were certain deposits in bank account, which were un-disclosed, so additions were made by the Assessing Officer and in the circumstances, only addition to the extent of peak credit in such bank account should be sustained. This plea of the assessee was accepted and the appeal of the revenue to tax the entire cash deposits was not accepted. 14) In this appeal, the contention is advanced by the assessee that each and every entry qua....