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PCIT v. Shri Krishan Lal Madhok ( 2022) BCAJ – November -P. 56 ( Delhi)( HC)

S. 69 :Unexplained investments -Peak credit – Amount disclosed and offered in one assessment year – Revenue bifurcating in to two assessment year – Rate of tax in same in both assessment year – Appeal of Revenue dismissed as there is no loss to Revenue . [ S. 132(4)]

Dismissing the appeal of the Revenue the Court held that  the dispute has arisen only with respect to the relevant  assessment year . However , the ITAT has held that said amount was  declared at the behest of the Revenue  and the calculation of the peak credit was also at the behest of the tax authorities . Tax rate in both the assessment year is same  there is no loss to the revenue . Order of Tribunal affirmed . (ITA No. 3917 / Del/ 2017 & 6628 /Del/ 2017 dt 16 -9 -2022 )( AY. 2006 -07 , 2007 -08 )