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Issues involved:
1. Discrepancy in property value in Sainik Farms 2. Apportionment of undisclosed income Discrepancy in property value in Sainik Farms: The issue revolved around the value of the property in Sainik Farms, with the DVO's report indicating a higher value than what was disclosed by the assessee. It was acknowledged that no incriminating document suggesting undisclosed investment in the property was found during the search. The Tribunal emphasized the necessity for evidence found during search to establish undisclosed income, citing a judgment of the Madhya Pradesh High Court and a CBDT circular. The Court aligned with previous decisions, emphasizing the requirement for evidence found during search to support claims of undisclosed income. In this case, as no material was discovered during the search to indicate undisclosed income related to the Sainik Farms property, the AO's conclusion was solely based on the assessee's return and the DVO's report. Consequently, no substantial question of law was deemed to arise on this issue. Apportionment of undisclosed income: The Revenue's counsel expressed interest in examining the issue of apportioning undisclosed income amounting to Rs. 10,59,700. The matter was adjourned to allow for further submissions specifically on this aspect, with a scheduled date of 10th November 2008.
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