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TMI Blog2012 (1) TMI 233X X X X Extracts X X X X X X X X Extracts X X X X ..... O R D E R Per Sanjay Arora, AM: These are a set of nine Cross Appeals by the Assessee and the Revenue arising out of the separate Orders by the Commissioner of Income-tax (Appeals)-I, Kochi ( CIT(A) for short) of even date, i.e., 15-06-2010, deciding the assessee s appeals contesting its assessment u/s.153C r.w.s. 153A 143(3) of the Income-tax Act, 1961 ('the Act' hereinafter ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... has accepted the Revenue s stand for two assessment years, i.e., A.Y. 2003-04 2007-08, i.e., in respect of which the evidence was found in search. For the other years covered by the assessments, only the suppression of income was inferred on the basis of the presumption that the same represented the assessee s modus operandi, in operation since the previous year relevant to A.Y. 2001-02, the ear ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... suppression commence only with effect from December, 2006. She was specifically queried by the Bench as to if any specific query in relation to the assessee was made by the Revenue in the statements of Accountant and partner under section 132(4) of the Act being relied upon, and to which she answered in the negative. Also, she sought to distinguish the facts of the instant case, further submittin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e evidence would show a systematic suppression of the income, and which was being regularly monitored by the partners, and withdrawn by them. 4. We have heard the parties, and perused the material on record. Admittedly, no fresh facts or materials, i.e., other than those already considered by the tribunal in the case of Matha Enterprises (supra) has been brought to our notice. The decision by t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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