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TMI Blog2019 (2) TMI 1593X X X X Extracts X X X X X X X X Extracts X X X X ..... nk would not established a relation between the payable amount and the assessee, particularly when the draft was in favour of a limited Company. As recorded, documents were not seized from the possession of the Assessee but during the raid from a third party. No question of law, therefore arises. Addition of unexplained expenditure - HELD THAT:- Tribunal considered the material on record and re ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the presumptions envisaged in the provisions of Section 132(4A) as well as provision of Section 292C are squarely applicable in the case of the assessee and consequently the AO was justified in treating the said amount as the assessee's unexplained income? (b) Whether on the facts and circumstances of the case and in law, the Tribunal was justified in restricting the addition on account o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the the RespondentAssessee, payable in India. The Assessing Officer added Indian Rupees, equivalent of such sums in the hands of the Assessee. The issue eventually reached to the Tribunal. The Tribunal by the impugned judgment, confirmed the addition in relation to bank draft in the name of the Assessee, whereas addition in connection with the bank draft in favour of the Pan Asian Distribution Ltd ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Income Tax Act, 1961 (in short the Act ) in such a case would not arise. Entire issue is thus factual. 4 Counsel for the Revenue, however, vehemently contended that, during the search operation, Revenue Authorities had found a document in the nature of letter from the bank, pointing out that, the last date for presentation of the draft in question had expired and that the Assessee should get t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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