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TMI Blog2023 (9) TMI 794X X X X Extracts X X X X X X X X Extracts X X X X ..... counted money by way of shell companies and putting them into a series of transactions to give a legitimate colour of converting of unaccounted cash available with the individuals - HELD THAT:- Appellant had nowhere contested the applicability of the provisions of sec.56(2)(vii)(b) of the Act to the transactions Challenge for year of transaction was rightly dislodged by the Ld. CIT(A) as well a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... (A)-2/PNJ/10176/2018-19, dated 24.01.2022, involving proceedings u/s. 143(3) r.w.s. 147 of the Income Tax Act, 1961 (in short the Act ). 2. Briefly the facts of the case are as under : The assessee-appellant is an individual, filed his return of income for the assessment year 2011-12 on 21.01.2012 declaring total income of Rs. 65,390/-. Subsequently, a search and seizure action u/s. 132 of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... erence is more than Rs. 50,000/-, the transaction is hit by the provisions of sec.56(2)(vii) of the Act. Accordingly, the Assessing Officer brought to tax a sum of Rs. 1,56,25,000/-. 2.1. Being aggrieved by the above assessment order, the assessee-appellant filed an appeal before the CIT(A) who vide impugned order dated 24.01.2022 held that it was a perfect example of a fa ade created to conver ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rities and the material available on record. We find that the Ld. CIT(A) has discussed the factual matrix of the case in great detail vide para 7.1 of his order. For the sake of brevity, the facts are not repeated/discussed herein. From the perusal of the CIT(A)'s order, it is clear that the appellant had nowhere contested the applicability of the provisions of sec.56(2)(vii)(b) of the Act to ..... X X X X Extracts X X X X X X X X Extracts X X X X
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