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TMI Blog2014 (10) TMI 582X X X X Extracts X X X X X X X X Extracts X X X X ..... rsing the judgment of learned CIT(A) and making the impugned addition by invoking the provisions of Section 69A of the Income Tax Act, 1961 in 1998-99 is misconceived in view of the bills of purchase of jewellery pertaining to assessment year 1987-88? B. Whether under the facts and in the circumstances of the case and in view of legal provisions, the ITAT was justified in confirming addition for assessment year 1998-99 on account of jewellery purchased and declared for assessment year 1987-88 under VDIS Scheme? C. Whether under the facts and in circumstances of the case and in view of legal provisions, the ITAT was justified in going into the source of acquisition of jewellery for assessment year 1987-88 where no proceedings were pending ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e assessee was not accepted and the cheque was returned back to her. The appellant filed return of income declaring income at Rs. 28,956/- for assessment year 1998-99 and notice under Section 148 of the Act was issued to the appellant on 31.3.2005 for the assessment year 1998- 99 on the ground that she had made declaration under VDIS 1997 but had not made payment of taxes due on declared amount and hence income of Rs. 10,19,809/- being the amount of jewellery declared therein escaped assessment. The Assessing Officer vide order dated 28.3.2006, Anenxure A.1 made addition of Rs. 21,47,176/- valuing the jewellery declared in the year 1986-87 at Rs. 10,19,809/- as per approved valuer report as on 31.3.1997 by adopting its value as on 31.3.1998 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er consideration before the Tribunal wherein the impugned order dated 24.9.2013, Annexure A.5 was passed. Hence the instant appeal by the assessee. 3. We have heard learned counsel for the appellant and perused the record. 4. The Tribunal while allowing the appeal of the revenue recorded as under:- "20. The learned AR for the assessee, time and again has pointed out that the said jewellery which was declared to be purchased in the financial year 1986-87 cannot be included as income from undisclosed sources in the hands of the assessee in assessment year 1998-99. In the abovesaid facts and circumstances of the case, where the assessee has failed to offer an explanation about the nature and source of acquisition of the said items of jewell ..... X X X X Extracts X X X X X X X X Extracts X X X X
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