2013 (2) TMI 21

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..... epresents certain loans given by the assessee to various persons. Also that after discovery of the document during survey, the Revenue should have either obtained further information or in any case should have conducted more enquiries to prove the contents of the document and that without such enquiry or any material on record, it is not possible to return a finding that the figures are in terms o .....

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..... Rs. 67,96,725/- (Rs. 64,00,000/- + 3,96,725/- int.) made by the AO on account of unexplained investment by ignoring the fact that the assessee failed to discharge the onus of proof that noting contained on the piece of paper did not relate to any transaction. ii) Whether on the facts and circumstances of the case, the Hon'ble Income Tax Appellate Tribunal is justified in disallowing the addition .....

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..... tents of the document and that without such enquiry or any material on record, it is not possible to return a finding that the figures are in terms of lakhs and lead to addition to income. We have asked learned counsel for the appellant to explain that the entries so recorded relate to transaction of money. It is argued that conduct of the assessee during the course of survey would cause inferen .....

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