2025 (8) TMI 1421

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....or The Revenue : Smt. Kusum Bansal,CIT, DR ORDER PER RAJ PAL YADAV, VP The Revenue is in appeal before the Tribunal against the order of the Commissioner of Income Tax (Appeals) [in short 'the CIT (A)'] dated 11.08.2023 passed for assessment year 2018-19. 2. Though the Revenue has taken three grounds of appeal but its substantial grievance is confined to one issue namely, CIT(A) has er....

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....er was opened out of which gold and diamond jewellery was found. While explaining the source of acquisition, assessee had contended that Shri Abhishek Singla has withdrawn a sum of Rs. 83,80,000/- from M/s Sheetal Industries. It was further submitted that in the hands of M/s Sheetal Industries, the income of Rs. 2,80,00,000/- was surrendered which has been assessed to tax. Shri Anmol Singla withdr....

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....s jewellery was purchased. The AO did not accept this contention of the assessee and made the addition. 5. Dissatisfied with the above, the assessee carried the matter in appeal before CIT(A). Assessee has demonstrated the details vide which amount was surrendered and how that income was allocated to different items of assets. The ld. CIT(A) was satisfied with the explanation of the assessee an....

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.... The assessee has al located this against the building, land, withdrawals by partners, difference stock etc. This amount which was withdrawn by the partners, it is available in their hands. The Department cannot lay its hand on discovery of cash to the extent of Rs. 94,50,000/-. We could appreciate the case of the AO had a cash was recovered or unexplained expenditure was discovered during the sea....