2011 (8) TMI 616

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..... oan nor received any deposit and it is the director of the company who had utilized his undisclosed income for and on behalf of the assessee. The Income-tax Appellate Tribunal has recorded a finding of fact that the director had explained the source of his undisclosed income and the said explanation has been accepted by the Department. Thus, in the present case, there was no question of receiving .....

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..... ere seized. In the proceedings initiated under section 153C of the Income-tax Act, 1961, the said Mr.Kiran Shah offered to tax the undisclosed expenditure incurred by him for and on behalf of the assessee-company for construction activities. 3. Accordingly, journal entries were passed in the assessee's books of account in respect of the said expenditure incurred by the director on behalf of th .....

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..... has recorded a finding of fact that the director had explained the source of his undisclosed income and the said explanation has been accepted by the Department. Thus, in the present case, there was no question of receiving any amount by the assessee as a loan or deposit from the director of the assessee. In these circumstances, deletion of penalty imposed under section 271D of the Income-tax Act, .....

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