9911796707
TMI Blog2011 (3) TMI 1689X X X X Extracts X X X X X X X X Extracts X X X X ..... y the Revenue is directed against the order of the Ld. Commissioner of Income Tax (Appeals) dated 27.11.2009 pertaining to assessment year 2007-08. 2. The issue raised is that Ld. Commissioner of Income Tax (Appeals) erred in deleting the addition of 50,00,000/- made on protective basis which represented unexplained cash of M/s SAS Servizio Ltd. of whom the assessee was an employee. 3. In th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... state to whom it was given and for what purpose. In fact the company got the letter of allotment on 25.08.2006 and there is no close and proximate linkage between the happening of the two events. Moreover, assessee was not able to offer any satisfactory explanation of why such money could not be brought into regular books or allowed to remain in the bank till it was needed. In any case, the asses ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... y and as a matter of abundant precaution since it has been recovered from him it is assessed protectively in the hands of Sh. Sundeep Kalsi. 4. Upon assessee s appeal Ld. Commissioner of Income Tax (Appeals) elaborately considered the issue and held as under:- I have considered the submission as well as contentions of the appellant and the Assessing Officer making the impugned addition. I ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... under section 153C of the Income Tax Act, 1961. It is also evident that from the facts as elaborated by the Assessing Officer and also by the appellant, there is no doubt either in respect of assessee or in respect of assessment year about cash of ` 50,00,000/- found in possession of the appellant. In view of the facts of the case, I am of the opinion that the addition of ` 50,00,000/- in the han ..... X X X X Extracts X X X X X X X X Extracts X X X X
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