2017 (8) TMI 1751

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....vi, Adv. For the Respondent : Mrs.Ruby George, CIT ORDER PER GEORGE MATHAN, JUDICIAL MEMBER: ITA Nos.719 to 725/Mds/2017 are appeals filed by the assessee against the Order of Commissioner of Income Tax (Appeals)-19, Chennai, in ITA No.106, 105, 104, 103, 102, 101 & 100/15-16 dated 15.03.2017 for the AYs 2007-08 to 2013-14 . 2. Mrs.Ruby George, CIT represented on behalf of the Reven....

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....e assessment by making the disallowance by applying the provisions of Sec.14A r/w Rule 8D of the Act. It was a submission that at the outset, the assessments were liable to be annulled in so far as no incriminating material had been found in the course of the search or used for the purpose of the assessment proceedings. It was also a submission that statements recorded have also not been given to ....

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.... Rule 8D was liable to be deleted. The Ld.AR placed reliance upon the decision of the Co-ordinate Bench of this Tribunal in the case of Om Shakthi Agencies (Madras) (P) Ltd. V. DCIT reported in 66 taxmann.com 287 and also the decision of the Hon'ble Bombay High Court in the case of Continental Warehousing Corporation Ltd. Vs. CIT reported in [2015] 58 Taxmann.Com 78 (Bom) and also the decision of ....

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....talks of the main source of the income of the assessee being mysterious "other source" which has not been explained with evidence. A perusal of the order of the Ld.CIT(A) in Page Nos.12, Para No.4 talks of statement on oath recorded as well as the business practices discovered during the course of the search which have been the basis on which adverse inferences have been drawn as regards the incom....