TaxTMI 
TaxTMI 
2012 (8) TMI 1235
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....ent 1 : None. ORAL JUDGMENT PER : HONOURABLE MR. JUSTICE N.V. ANJARIA The above captioned appeals preferred by the Revenue under Section 260A of the Income Tax Act, 1961 arises out of the common order dated 29th October, 2010 of the Income Tax Appellate Tribunal, Rajkot Bench, Rajkot passed in ITA No. 173, 174 and 175 of 2009 in respect of Assessment Years 1992-1993, 1993-1994 and 1994-1995 re....
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.... its office premises on 23/24.06.1994, it was revealed that several bank accounts, FDRs, IVPs etc. were maintained by the appellant and one Swami Keshvanand. The assessment under sec. 143(3) read with sec. 147 of the Act was completed and the additions were made on account of FDRs & bank accounts etc. 3.1 The above income was added in the hands of Swami Keshavanand on substantive basis, whereas a....
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....hat investment in FD/bank accounts etc. is assessed on protective basis in the hands of the appellant and interest on these investments is also assessed on protective basis in the hands of the appellant. In para-7 of the order in all the above assessment years, the AO has also recorded that the demand on addition of Rs. 19,43,000/-, Rs. 4,38,000/- and Rs. 57,90,974 in the above assessment years re....
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....ncome Tax Appellate Tribunal. That appeal came to be dismissed as per the impugned common order. The Tribunal recorded the following findings : ".......The substantive additions are in the hands of Swami Keshavanand. In that case also penalty u/s 271(1)(c) of the Act has been levied for assessment years, 1992-1993, 1993-1994, 1994- 1995, 1996-1997, 1997-1998 and 1998-1999 and the ITAT vide ITA N....