PNK Space Development P. Ltd. v ITO (2024)110 ITR 71 (SN)(Mum)(Trib)

S. 147 : Reassessment-Accommodation entries-Information based on search action-Reassessment is valid-Depreciation-Disallowance is justified-Income from undisclosed sources-Addition is justified. [S. 32(1)(ii), 143(1), 148]

Held that the reassessment is valid. On merit the assessee had failed to furnish, either before the lower authorities nor before the Tribunal, the copy of bill, invoice, payment details and installation certificate in support of its claim to depreciation under section 32(1)(ii) of the Act on fixed assets put to use during the year. In the absence of such documentary evidence, there was no reason to interfere with the order of the authorities. As regards income from undisclosed source even before the Tribunal, the assessee had not filed any evidence in support of its claim. Addition is affirmed. (AY.2012-13)