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2004 (12) TMI 53

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..... 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 accepted the explanation offered by assessee, thereby upholding the view of the Commissioner of Income-tax (Appeals). As a consequence, certain .....

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..... out under section 260A of the Act that being the prerequisite for admission of appeal. Heard Shri A. P. Patankar, 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 two questions proposed by t .....

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..... ered by the assessee in relation to the impugned additions made by the Assessing Officer and held that since the same have been properly explained 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 o .....

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..... or it is absurd to the extent that no reasonable prudent man can ever reach such conclusion, or it is against the provision of law, that 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 .....

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