2023 (8) TMI 769

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....exure A-4) passed by the Income Tax Appellate Tribunal, Chandigarh Bench 'A', Chandigarh in ITA No.1266/Chd/2017 and ITA No.1304/CHD/2017, for the assessment year 2012-2013, whereby appeal filed by the revenue has been dismissed, whereas the appeal of the assessee has been allowed. While passing the impugned order, the Tribunal had decided three appeals together i.e. ITA No.739/Chd/2016 (preferred by the department in the case of M/s Halcyon Life Sciences Pvt. Ltd), ITA Nos.1266.Chd/2017 and 1304/Chd/2017 (cross appeals, out of which present appeals have arisen) against the order dated 19.062017 passed by the Commissioner of Income Tax (Appeals) - 3, Gurgaon. In the case of present assessee i.e. Ind.Swift Group of Companies (ITA No.1304/C....

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....e above said amount, which was surrendered, did not relate to any information, which had been got from the seized documents. Hence, the amount of Rs. 1,77,00,000/- would fall within the definition of undisclosed income as per Section 271AA of the Act. The said section is reproduced as under:- "(a) "undisclosed income" means- (i)any income of the specified previous year represented, either wholly or partly, by any money, bullion, jewellery or other valuable article or thing or any entry in the books of account or other documents or transactions found in the course of a search under section 132, which has-- (A) not been recorded on or before the date of search in the books of account or other documents maintained in the normal course re....