2026 (4) TMI 468

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....hereinafter referred to as 'the Act') passed by the ACIT, Central, Karnal for AY: 2021-22. 2. A search and seizure action u/s 132(1) of the Act was carried out at the business premises of Unique Group and residential premises of its director and family members on 11.01.2022. The assessee is connected with group and was also covered under the search. The assessment in case of assessee for AY: 2021-22 was concluded u/s 143(3) of the Act by order dated 30.12.2022 at returned income. 2.1 However, the ld. Revisionary Authority was not satisfied and believed that AO had failed to verify cash receipt/payments recorded in certain seized material and AO has failed to consider survey statement of Satish Kumar. 3. The contention of ld. Counse....

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....nt facts and circumstances and the evidences the assessing officer observed in para 5.3.4 & 5.3.5 as follows: "5.3.4 In view of the above, it is observed that assessee has deliberately decided to not explain the contents of these documents as they have no explanation about the source of various unaccounted cash received and cash payments entries mentioned on the various pages of Annexure A-1. On perusal of Annexure A-1 impounded from the premises, it is noticed that various figures in lakhs of rupees are mentioned on different pages wherein cash receipts and cash payment entries were mentioned. On perusal of page no. 8 to 12 of Annexure A-1, it is noticed that the total cash receipts comes to Rs. 5,07,84,500/- which remained unexpl....

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.... (i) that such books of account, other documents, money, bullion, jewellery or other valuable article or thing belong or belongs to such person; (ii) that the contents of such books of account and other documents are true; and (iii) that the signature and every other part of such books of account and other documents which purport to be in the handwriting of any particular person or which may reasonably be assumed to have been signed by, or to be in the handwriting of, any particular person, are in that person's handwriting, and in the case of a document stamped, executed or attested, that it was duly stamped and executed or attested by the person by whom it purports to have been so executed or attested.". ....