9911796707
TMI Blog2004 (6) TMI 21X X X X Extracts X X X X X X X X Extracts X X X X ..... ssessment proceedings initiated against the assessee u/s 158BC - No error could be noticed by us in the impugned order - Tribunal did go into the details of the explanation offered by the assessee and accepted the explanation thereby upholding the view of the Commissioner of Income-tax (Appeals). As a consequence, certain additions made came to be deleted - We thus, do not find any merit in the ap ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ant. Having heard learned counsel for the appellant and having perused the record of the case, we are of the opinion that the appeal does not involve any substantial question of law for consideration in this appeal and that the two questions proposed by the appellant (Revenue) do not satisfy the rigour of substantial question of law within the meaning of section 260A of the Act. The issue rela ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... they cannot be included while computing the total income of the assessee. Since, it was a case of raid, and hence, the assessee was called upon to explain the source of income so as to enable the Assessing Officer to determine the actual taxable liability arising out of the raid proceedings. In our opinion, once the Commissioner of Income-tax (Appeals) and then lastly the Tribunal have accepted t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ion of law, a case for substantial question of law is made out. In our view, no such error could be noticed by us in the impugned order. The Tribunal did go into the details of the explanation offered by the assessee and accepted the explanation thereby upholding the view of the Commissioner of Income-tax (Appeals). As a consequence, certain additions made came to be deleted. We thus, do not f ..... X X X X Extracts X X X X X X X X Extracts X X X X
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