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TMI Blog2016 (8) TMI 1212X X X X Extracts X X X X X X X X Extracts X X X X ..... the loose paper with the business of assessee. The nature of notings wherein amount has been calculated at four different rates indicate that it is a rough noting. The revenue has not been able to furnish any finding as to what is the amount of loan, to whom advanced, source of the loan etc. We are in complete agreement with the reasonings arrived at by the CIT(A). The order passed by the Tribuna ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , the revenue has preferred the present Tax Appeal for consideration of the following substantial questions of law: (1) Whether the Appellate Tribunal is right in law and on facts in confirming the order passed by the CIT (A) in deleting the addition of ₹ 53,44,738/- made on account of unexplained receipts of funds recorded on page Nos. 41 and 48 of Annexure A-15? (2) Whether the Appe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... gainst NIL income filed by assessee. the On appeal the CIT (Appeals) allowed the same and deleted all the additions made by the Assessing Officer. 3. On appeal before the Tribunal by the revenue, by impugned judgment and order, Tribunal confirmed the findings of CIT(A). Being aggrieved and dissatisfied with the impugned order passed by the Tribunal, the revenue has preferred the present Tax App ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Annexure A-29 transpire to be the interest receipts by the assessee derived from unaccounted monetary dealings and therefore the same was treated as assessee s income for the block year under assessment. 5. Mr. B.D. Karia, learned advocate appearing with Mr. Darshan Patel, learned advocate on behalf of Mr. R.K. Patel, advocate for the assessee submitted that the CIT(A) as well as the Tribunal h ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... that it is a rough noting. The revenue has not been able to furnish any finding as to what is the amount of loan, to whom advanced, source of the loan etc. We are in complete agreement with the reasonings arrived at by the CIT(A). The order passed by the Tribunal is required to be confirmed and the questions raised in the present appeal is required to be answered in favour of the assessee. 7. A ..... X X X X Extracts X X X X X X X X Extracts X X X X
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