Held that the Assessee has admitted receipt of on-money on the sale of property during the course of search and post-search enquiries which is further fortified by the incriminating material found during the course of search., The contention of the assessee that the said amount is capital receipt, on account of sale of agricultural land was rejected. Addition was confirmed. The Tribunal also held that the Assessee has neither explained the loose sheets found during the course of search, which contain chit and finance business transactions nor reconciled total loans and advances outstanding as on date of the search and offered income from chit and moneylending business, the addition made by the AO towards the remaining undisclosed income from chit and finance business is sustained. (AY. 2017-18)
A.Jhonkar v. Dy. CIT v. Johnkumar Trust (2022) 220 TTJ 187 (Chennai) (Trib) Dy. CIT v. Johnkumar Trust (2022) 220 TTJ 187 (Chennai) (Trib)
S. 153A : Assessment-Search or requisition-On money on sale of property-Loose sheets-Agricultural land-Undisclosed income-Found in the possession of buyers-Capital receipt-Admitted the receipt of on money-Cannot be treated as capital receipt-Addition is justified. [S.2(14)(iii), 4, 132]