2016 (5) TMI 696

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..... ITA 668 of 2015 & CM No. 17302 of 2015 (for condonation of delay in refiling the appeal) 1. The reason for delay of 521 days in re-filing the appeal, as explained in the supplementary affidavit dated 10th May 2016 filed by the Appellant, is that on account of the changed procedure of e-filing of appeals, the delay has occurred. 2. This Court has in a number of similar applications filed by the .....

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..... lant on a protective basis of the sum of Rs. 1,80,32,087 under Section 68 of the Income Tax Act, 1961 ('Act'). The AO disbelieved the case of the Appellant that he received a gift of Rs. 1.8 crores from one Mr. Sanjay Mohan Agarwal and then transferred the money in favour of his son-in-law Mr. Amar Khosla and his grand children. The AO held that the Assessee was unable to satisfactorily explain th .....

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..... f the present case it is clear that the Assessee has no valid explanation regarding the source of his income for making gifts to the tune of Rs. 1.8 crores during the AY in question. The person he named as the source was an accommodation entry provider. The addition was made on substantive basis in the hands of Mr. Amar Khosla and on protective basis in the Appellant's hands. The addition in M .....

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