Dy. CIT v. Global Wool Alliance Pvt. Ltd. (2022)100 ITR 12 (SN) (Kol.) (Trib.)

S. 69 : Unexplained investments-Income from undisclosed sources-Notice returned unserved with the remarks “Not found” or “Left”-Payments were though account payee cheques-tax was deducted at source-Addition is not justified. [S. 133(6)]

Held, that in respect of both these parties all the necessary material and evidence such as bills, vouchers and rate contract were placed before the Assessing Officer as well as Commissioner (Appeals) and the payments were made by cheques after proper deduction of tax and similarly invoices for the commission paid  after deduction of tax with reference to sales effected by him were placed on record. Deletion of addition is justified. (AY.2005-06)