Held that the search operation was carried out based on valid information gathered against the assessee along with associates/relatives, and large-scale unaccounted investments were found by the Department during the relevant year, proceedings under S. 153A cannot be said to be illegal. The assessee failed to substantiate the source of the gift given by the grandmother; the addition was affirmed. As regards s no contrary evidence was filed by the assessee before the Assessing Officer as well as the CIT(A) during proceedings, therefore, the addition made by CIT(A) was sustained. (AY.1998-99 & 2001-02 to 2004-05)
Kumar Suman Singh v. ACIT (2025) 234 TTJ 85 / 171 taxmann.com 801 (Pat)(Trib)
S. 153A: Assessment-Search-Valid information-Proceedings are valid-Cash credits-Gift-Grandmother-No source to substantiate the gift-Addition was affirmed-Unexplained expenditure-Household expenses-Addition was affirmed.[S.68, 69C]
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