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2004 (7) TMI 56

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..... in the course of block assessment proceedings initiated against the assessee under section 158BC of the Act. The Assessing Officer did not accept the explanation offered by the assessee and treating the said amount to be that of the assessee added in his total income - Tribunal set aside the order of the Assessing Officer in so far as it related to additions made by him (AO). - Once the Tribunal h .....

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..... ct that being the pre-requisite for admission of appeal. Heard Shri R. L. Jain learned counsel for the appellant. 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 sa .....

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..... lained, they cannot be included while computing the total income of the assessee. Since it was a case of raid, 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 Tribunal has accepted the explanation of the assessee and accordingly, deleted certa .....

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..... 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 deleting the additions. As a consequence, certain additions made by the Assessing Officer came to be deleted. We thus, do not find any merit in the appeal. It fails and is dismissed in limine by holding that it .....

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