Akhtar Hasan Rizvi v. JCIT [2025] 179 taxmann.com 636 (Bom)(HC)

S. 158BD: Block assessment-Undisclosed income of any other person-Architect’s cross-examination confirmed cash payments made by the assessee; since concurrent findings of fact established the Assessing Officer’s satisfaction, undisclosed income was rightly assessed under section 158BD and not under section 69C. [S. 69C, 132, 260A]

Where, pursuant to a search at the premises of the assessee’s architect, the Assessing Officer issued notice under section 158BD and the architect, on cross-examination, confirmed cash payments made by the assessee, and concurrent findings of fact established that the Assessing Officer had satisfied himself regarding suppression of income, undisclosed income was rightly assessed under section 158BD; mere reference to statutory provisions and contention that expenditure had been disclosed did not give rise to any substantial question of law. Editing the summary of case laws.(AY. 1986-87)

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