2025 (9) TMI 236

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.... ORDER PER BENCH : This is an appeal filed by the revenue against the order of the Commissioner of Income Tax (Appeals)-27, Kolakta [hereinafter referred to as the 'CIT(A)'] in appeal no. CIT(A), Kolkata-21/10856/2018-19 dated 27.02.2024 for assessment year 2019-20. 2. None represented on behalf of the assessee and Shri Mangthilen Haokip, Sr. DR represented on behalf of the revenue. ....

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.... Shri Bivas Kedia in so far as he was detained by Railway Police Authority on 27.05.2019 at Asansol as he was carrying cash amounting to Rs. 1,00,00,000/- without any documentary evidence. In the statement recorded from Shri Bivash Kedia, he has mentioned that the money belonged to M/s Pratik Steel Casting Pvt. Ltd. The said Rs. 1,00,00,000/- was also held to be belonged to the assessee and the as....

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....een found and which has been accepted by the assessee would not have been disclosed in the returns filed, the penalty as levied is liable to be upheld. It was submitted that the order of the ld. CIT(A) is liable to be reversed. 5. We have considered the submission and also perused the orders of the authorities below. The facts in the present case clearly show that search and seizure operation h....

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....tted undisclosed income during the search. However, there is no recording of when this search has taken place on the assessee and there is no reference to any search having been conducted on the assessee. The Assessing Officer further holds that the assessee has substantiated the manner in which such undisclosed income was earned but he has not paid due tax on such undisclosed income for the speci....