2024 (2) TMI 702

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....ldyal For the Respondent : Suyash Agarwal ORDER 1. Heard Sri Manu Ghildyal, learned counsel for the Union of India-Revenue and Sri R.R. Agrawal, learned Senior Advocate, assisted by Sri Nitin Kumar Kesharwani, learned counsel counsel for the assessee. 2. Present appeal has been filed under Section 260-A of the Income Tax Act, 1961 (hereinafter referred to as the Act) arising from the o....

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....ercise his powers of inquiry from jeweller or from other available open sources to establish any suspicion, especially in view of the fact that the AO had given many opportunities to the assessee for providing the source and proof of old jewellery sold by the depositor or to provide wealth tax return of old jewellery? 2. Whether, in the facts and circumstances of the case and in law, the ....

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....ny attempt to exercise his powers of inquiry from jeweller or from other available open source to establish any suspicion." 5. Thus it is seen that other than the suspicion raised by the assessing officer as to the genuineness of the transaction, no credible/ tangible material was brought on record by the assessing authority as may have led to any satisfaction or finding that the transaction wa....