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TMI Blog2021 (9) TMI 910X X X X Extracts X X X X X X X X Extracts X X X X ..... same time, non-explanation of the source cannot be brushed aside lightly. We find that search party had seized only ₹ 2 lakhs which means that the search party itself must have accepted the source for ₹ 54,200/-. In light of these facts, we direct the Assessing Officer to restrict the disallowance to ₹ 2 lakhs only. The assessee shall get part relief. - ITA No. 2061/DEL/2018 - ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ction on 27.12.2013 in Metenere Group and the assessee was part of the search operations. During the course of search proceedings, cash amounting to ₹ 2,54,200/- was found, out of which ₹ 2 lakhs was seized. 4. On a specific question asked by the Investigation Officers to explain the source of cash of ₹ 2,54,200/-, the assessee replied that it was out of savings of past 10 yea ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... any plausible reply and stated that out of ₹ 2,54,200/-, only ₹ 2 lakhs were seized and, therefore, addition should be sustained to that extent. 7. The ld. DR strongly supported the findings of the lower authorities. 8. We have carefully considered the orders of the authorities below. It is true that the assessee is a Senior Citizen of 75 years of age. Therefore, it can be easil ..... X X X X Extracts X X X X X X X X Extracts X X X X
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