Assessee is firm engaged in the business of construction. On the basis of noting on the seized paper found during the course of search with Mr. X, and his admission before ITSC . Notice U/sec 153 C was issued and AO with approval of Addl CIT made the addition of the amount mentioned in the seized papers as undisclosed investment of loan in the hands of assessee u/sec 68 of the Act. Before completion of assessment proceedings Addl CIT has initiated Penalty proceedings u/sec 271D and also levied the penalty U/ 271D on reliance on the same papers . Whether the Action of AO and Addl CIT is justified in Law.
assessee has also asked for effective  Cross examination, application of the X before ITSC and order of ITSC , however AO has denied the same as it is confidential and drawn the inference that assessee has avoided to take cross examination .
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