2004 (12) TMI 298

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....in relation to the block period 1st April, 1989 to 27th July, 1999. 2. The facts apropos to ground NO.1 are that search action was taken under s. 132 of the IT Act on 27th July, 1999 in respect of St. Soldier School and Sh. Anil Chopra group concerns covering business and residential premises of Sh. Anil Chopra, his family members and others, including residential premises situated at 331, SUS,....

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....h the explanation of this document. It was stated that all the investments made by the assessee were found by the Department and there was nothing which remained to be detected. Further enquiries were conducted and it was found that this locker was opened in March, 1998. Since this paper was bearing date of 15th Dec., 1997, the AO opined that the same was prepared prior to the opening of locker in....

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....of Rs. 5.69 lakhs is some loose paper found in the locker containing entries of IVPs worth Rs. 33.42 lakhs. There is no dispute that the IVPs worth Rs. 27.33 lakhs were actually found which became the subject-matter of taxation. Apart from that, the AO made addition of Rs. 5.69 lakhs on account of IVPs which in his opinion, the assessee might have sold or placed somewhere else. It is important to ....

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....ng has been brought on record even to remotely suggest that the assessee had made investment in IVPs to this extent, we are of the considered opinion that the learned CIT(A) was justified in deleting this addition. 3. Second ground deals with the deletion of addition of Rs. 3,52,600 made on account of difference in FDRs. On the basis of same paper extracted above mentioning FDRs at Rs. 4.61 lak....