9911796707
TMI Blog2022 (12) TMI 1168X X X X Extracts X X X X X X X X Extracts X X X X ..... tion offered by him is not satisfactory in the opinion of the Assessing Officer, the sum so credited may be charged to income tax as to the income of the assessee of that previous year. Therefore, what has to be inquired into by the AO is about the nature and source of the deposit. If the explanation with regard to the nature and source is found unsatisfactory, only then the amount so credited may ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ation The amendment application seeking amendment in the substantial question of law framed in the memo of appeal is found to be formal in nature. No objection has been taken by Sri Krishna Agarwal, learned counsel appearing for the respondent-Revenue. The amendment application is allowed. Necessary amendments be incorporated during the course of the day. On Memo of Appeal Hea ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... fficer is about the nature and source of the deposit. If the explanation with regard to the nature and source is found unsatisfactory, only then the amount so credited may be treated is income. Section 68 came up for consideration in the decision in the case of Anil Rice Mill vs. Commissioner of Income Tax reported in 2005 Law Suit (All) 1051), relied upon by the learned counsel for the petiti ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... essee as per Section 68 of the Income Tax Act, 1961, could not be proved by him. The burden would, therefore, not shift on the revenue, as the assessee has failed to discharge her burden. The assessee has failed to prove the transaction as per Section 68 of the Income Tax Act,1961. No question of law, much less substantial question of law, arises in the instant appeal for consideration and the ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
