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TMI Blog2013 (12) TMI 1255X X X X Extracts X X X X X X X X Extracts X X X X ..... ation – There is no justification for making the addition of Rs.16,40,000/- in the hands of the assessee. Unexplained payment - Held that:- The ITAT found that M/s. Mohan Lal Jain & Sons was having transaction with Sri Santosh Kumar Agrawal only. He was not having any transaction with the assessee firm. M/s. Mohan Lal Jain & Sons have repeatedly asked Sri Santosh Kumar Agarwal, whose wife was a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Allahabad in ITA No. 207/Alld/2004; ITA No. 251/Alld/2004 and CO No. 6/Alld/2004, for the block period 01.04.1990 to 27.04.2000. The Appeal has been preferred on the following questions of law:- "Whether on the facts and in the circumstances of the case, the Hon'ble Income Tax Appellate Tribunal was justified in law in upholding the order of Ld. CIT(A), Allahabad granting relief of Rs.16,40,000 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... receipt of Rs.1,20,618/- without appreciating the facts of the case and material brought on record by the A.O.?" The Income Tax Appellate Tribunal, Allahabad in respect of addition of Rs.16,40,000/- observed as follows:- "21. After hearing both the parties and perusal of material on record, it appears that the impugned papers were found at the residential premises of Sh. Santosh Kumar Agrawal, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... having transaction with Sri Santosh Kumar Agrawal only. He was not having any transaction with the assessee firm. M/s. Mohan Lal Jain Sons have repeatedly asked Sri Santosh Kumar Agarwal, whose wife was a partner in the assessee firm, for making the payment, and Sri Santosh Kumar Agrawal has also confirmed it. On the third question regarding addition of Rs.1,20,618/-, the ITAT held that profit ..... X X X X Extracts X X X X X X X X Extracts X X X X
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