TMI Blog2019 (12) TMI 1452X X X X Extracts X X X X X X X X Extracts X X X X ..... 734/- as reflected in Stay Petition filed by assessee with Income Tax Appellate Tribunal, Chennai Benches, Chennai. 2. The back ground of the assessee's case in brief is that the assessee was searched by Revenue u/s 132 of the Income-tax Act,1961, as part of searches conducted by Revenue against Lalitha Jewellery Group of cases on 02.09.2014 , wherein Residential Premises of the assessee was also searched by Revenue. During the course of search, the assessee made surrender of an amount of Rs. 20,00,00,000/- as undeclared income for the impugned ay: 2015-16 owing to various discrepancies in various documents and material seized by Revenue during the course of search operations relating to his properietory concern of the assessee engaged in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ing of statement in which it is claimed that the assessee did not disclosed the surrender income and it tantamounts of retraction which should be accepted. The Revenue authorities have rejected various contentions raised by assessee and have affirmed the additions to the tune of Rs. 20 crores in the hands of the assessee. The second additions to the tune of Rs. 76.19 crores was made by Revenue on the allegations that there was an infringement of provisions of Section 2(22)(e) of the 1961 Act as it is the money of Lalitha Jewellery Mart Private Limited which was advanced to assessee's properitory concern A K Exports through conduits created in between namely Infinity Jewellers and Mariyam Creations wherein sale and purchase of gold jewellery ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to argue its case at the earliest. The third main addition as was made by Revenue to the tune of Rs. 16.24 crores was towards treating long term capital gain claimed as an exempt by assessee u/s 10(38) of the 1961 Act as bogus/sham by Revenue authorities concurrently which was brought to tax. The authorities below have elaborately discussed after detailed investigation/analysis in their order that the claim of assessee for exemption u/s 10(38) of the 1961 Act arising on alleged purchase and sale of company namely Mahavir Advanced Remedies Limited is bogus/sham. The learned counsel for the assessee submitted that long term capital gains claimed exempt by the assessee was genuine and it is claimed by learned counsel for the assessee that in a ..... X X X X Extracts X X X X X X X X Extracts X X X X
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