TaxTMI 
TaxTMI 
2024 (12) TMI 1280
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....ench 'A' in I.T. (S.S.) A.No.137/Hyd/2005 and I.T. (S.S.) A.No.138/Hyd/2005. 3. I.T.T.A. No.188 of 2012 and I.T.T.A. No.196 of 2012 are filed against the common order dated 28.02.2006 passed by the Income Tax Appellate Tribunal, Hyderabad Bench 'B' in I.T. (S.S.) A.No.151/Hyd/2005 and I.T. (S.S.) A.No.139/Hyd/2005. 4. These appeals filed under Section 260A of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') were admitted on the following substantial question of law: "Whether on the facts and circumstances of the case, the Tribunal erred in holding that the assessee had not discharged the burden of proof and rebutted the presumption available to the revenue under Section 132(4A) of the Income Tax Act, 1961 while confirming....
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.... block period and there cannot be any addition with regard to the investment made in the shares. 7. The Assistant Commissioner of Income Tax after due verification of the records and after considering the reply submitted by the assessee, passed assessment order on 28.01.2005 holding that the assessee's undisclosed income for the block period is Rs.6,54,200/- and after deducting the tax, the assessee is liable to pay balance tax for an amount of Rs.4,12,158/- and penalty under Section 158 BC and 158 BD of the Act. Aggrieved by the said order, the assessee filed appeal before the Commissioner of Income Tax (Appeals)-I, Hyderabad and the appellate authority dismissed the appeal by its common order dated 22.08.2005. Thereupon, the assessee fil....
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...., learned Senior Standing Counsel for Income Tax Department submitted that the Assessing Officer after due verification of the records passed the order on 28.01.2005 by giving cogent findings and the said order was confirmed by the Commissioner of Income Tax (Appeals)-I, Hyderabad and further the appellate Tribunal also dismissed the appeal and confirmed the orders of the Commissioner of Income Tax (Appeals)-I, Hyderabad. It is also argued that the findings of fact recorded by the Assessing Officer of Income Tax as well as the Tribunal do not suffer from any infirmity warranting interference of this Court in these appeals under Section 260A of the Act. 11. We have considered the rival submissions made by both sides and have perused the rec....