Dy. CIT v. Nagin A. Vaghela (2024)116 ITR 25 (SN)(Ahd)(Trib)

S. 153A : Assessment-Search-Unsecured Loans-Unexplained income-Penalty-Amounts carried over from previous year cannot be assessed as undisclosed income of the current year-New loans-Failure to establish credit worthiness-Addition is affirmed-Unabated assessment-Purchase and sale of land-No addition can be made merely on the basis of annual information return. [S.68, 132, 271(1)(c), 276C]

Held that the amounts carried  over  from  previous year cannot be assessed as undisclosed income of the current year. As reagrds  new loans the assessee failed to establish credit worthiness hence the  addition is affirmed. As regards unabated assessment  in respect  of  purchase and sale of land,  addition can not  be made merely on the basis of annual information return.(AY.2011-12, 2012-13, 2014-15, 2017-18)

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