2025 (6) TMI 1302

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....ar, Sr. DR ORDER PER VIKAS AWASTHY, JM: This appeal by the assessee is directed against the order of Commissioner of Income Tax (Appeals)/Additional/Joint Commissioner of Income Tax(Appeals)-12, Mumbai (hereinafter referred to as 'the CIT(A)') dated 13.06.2024, for assessment year 2011-12. 2. Shri Gautam Jain, appearing on behalf of the assessee submits that the assessee is a s....

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....ee submits that the assessment for AY 2011-12 was reopened in the case of assessee only on the basis of statement of Dr. P. Mahalingam, Chairman/Trustee of Santosh Group of Institutions. A search and seizure operation u/s. 132 of the Income Tax Act, 1961(hereinafter referred to as 'the Act') was carried out on Santosh Group of Institutions on 27.06.2013. During survey certain documents/boo....

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....se of Santosh Group of Institutions certain incriminating material was found and seized which clearly indicating that the assessee has paid capitation fee of Rs.12,00,000/- in cash for admission of her daughter to the Medical course in Santosh Medical College. Dr. P. Mahalingam, Chairman of the Trust admitted accepting of donations/capitation fee in cash and offered the same to tax as unaccounted ....