Held that the Assessing Officer made the addition purely on presumption and guesswork without any evidence on record. As there was no perversity in the decision of the Commissioner (Appeals), his order was upheld. The funds available were explained by the assessee as disclosure made at the time of search and sale receipts declared in the audited balance-sheet showing application of specific percentage profit, which had been accepted by the Assessing Officer and the Commissioner (Appeals). The findings of the Commissioner (Appeals) in confirming a separate addition was perverse to the facts on record as the entire sale receipts stood explained.(AY.2015-16)
Dy. CIT v. Guru Nanak Milk Products (2024)114 ITR 344 /232 TTJ 325 (Amritsar (Trib)
S. 143(3): Assessment-Search and seizure-Cash deposit in bank-Undisclosed income-Unaccounted sale receipts-Sale Of Property-Addition made as percentage of profit on sale receipts-Further addition on loan and interest is deleted.[S. 132]
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