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The Tax Publishers2020 TaxPub(DT) 1091 (Mum-Trib) INCOME TAX ACT, 1961
Section 68
Since addition was made for deemed unaccounted scrap sale on basis of a document recovered in survey, which did not pertain to relevant year, thus, addition was made on a weaker footing. Further, there was no basis furnished by CIT(A) for estimating addition made therefore assessee was granted relief of 50% of total additions made by CIT(A).
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Income from undisclosed sources - Addition on account of deemed unaccounted scrap sale - Addition made on basis of a document recovered in survey, which did not pertain to relevant year -
Issue arose as to whether addition on account of deemed unaccounted scrap sale could be made in facts and circumstances of case and whether CIT(A) was justified in reducing said addition for each of assessment years under consideration. Held: Whole basis of placing reliance on a document, which did not pertain to year under consideration, itself made the addition on a weaker footing. Further, for none of estimations by CIT(A), there was no basis furnished by CIT(A). However, considering the totality of facts and circumstances of the case and the survey conducted in premises of assessee, assessee was held to be entitled for relief of 50% of total additions made by CIT(A).
REFERRED :
FAVOUR : Partly in assessee's favour
A.Y. :
IN THE ITAT, MUMBAI BENCH
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