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Issues Involved:
1. Addition of Rs. 3,26,000/- u/s 68. 2. Addition of Rs. 4,00,000/- u/s 68. 3. Addition of Rs. 5,26,000/- u/s 68. 4. Double taxation of Rs. 1,00,000/-. 5. Addition of Rs. 30,000/- u/s 68. 6. Addition of Rs. 7,00,000/- u/s 68. 7. Addition of Rs. 3,00,000/- u/s 68. 8. Addition of Rs. 2,00,000/- u/s 68. 9. Double taxation and doctrine of promissory estoppel. 10. Double additions across assessment years. 11. Charging of interest u/s 234B. Summary: Issue 1: Addition of Rs. 3,26,000/- u/s 68 The assessee contended that the cash creditor, Sh. Gurcharan Singh, had explained the source of the advance as his past savings and contributions from his sons. However, the cash creditor failed to provide evidence of these savings or contributions. The Tribunal upheld the addition, noting the lack of evidence to prove the creditworthiness of the cash creditor. Issue 2: Addition of Rs. 4,00,000/- u/s 68 The cash creditor, Sh. Harjeet Singh, denied giving any advance to the assessee. The assessee argued that the amount was forfeited in a later year to avoid double taxation. The Tribunal dismissed this argument, confirming the addition for the impugned year and directing the AO to ensure no double taxation in subsequent years. Issue 3: Addition of Rs. 5,26,000/- u/s 68 The cash creditor, Smt. Gurdarshan Kaur, could not be traced, and no explanation was provided by the assessee. The Tribunal confirmed the addition, noting the absence of any evidence or explanation for the cash credit. Issue 4: Double taxation of Rs. 1,00,000/- The assessee argued that Rs. 1,00,000/- was brought forward from an earlier year. However, no supporting documents were provided. The Tribunal upheld the addition, citing the lack of evidence. Issue 5: Addition of Rs. 30,000/- u/s 68 The assessee admitted that Rs. 30,000/- was forfeited from an advance given by Sh. Jatinder Pal Singh. The Tribunal confirmed the addition due to the lack of evidence proving the genuineness of the transaction. Issue 6: Addition of Rs. 7,00,000/- u/s 68 The assessee claimed that Rs. 7,00,000/- was forfeited from an advance given by Sh. Jasbir Singh and included in a later year's income. The Tribunal upheld the addition, noting the absence of any explanation or evidence for the cash credit. Issue 7: Addition of Rs. 3,00,000/- u/s 68 The assessee stated that Rs. 3,00,000/- was forfeited from an advance given by Smt. Ritu. The Tribunal confirmed the addition, citing the lack of evidence proving the genuineness of the transaction. Issue 8: Addition of Rs. 2,00,000/- u/s 68 The assessee admitted that Rs. 2,00,000/- was forfeited from an advance given by Sh. Parshotam Lal. The Tribunal upheld the addition due to the lack of evidence proving the genuineness of the transaction. Issue 9: Double taxation and doctrine of promissory estoppel The Tribunal rejected the assessee's argument regarding double taxation and the doctrine of promissory estoppel, confirming the additions made in the impugned year. Issue 10: Double additions across assessment years The Tribunal dismissed the assessee's argument of double additions, confirming the additions made in the impugned year. Issue 11: Charging of interest u/s 234B The Tribunal noted that charging of interest u/s 234B is mandatory and consequential, requiring no separate adjudication. Conclusion: The appeal of the assessee was dismissed in its entirety, with all grounds of appeal being rejected. The Tribunal confirmed the additions made by the AO and the CIT(A) and upheld the charging of interest u/s 234B.
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