9911796707
TMI Blog2023 (10) TMI 366X X X X Extracts X X X X X X X X Extracts X X X X ..... s worth noting that the assessee has been a regular filer of income tax returns for the past three years and has declared income exceeding Rs. 10 lakhs for the relevant assessment years prior to the current one, which supports the assessee s claim that the undisclosed income of Rs. 10 lakhs can be explained from past accumulations or savings and we do not find assessee s contention as an after thought. Since the assessee failed to provide sufficient evidence before the Assessing Officer and he had only raised the plea before the ld. CIT(A), hence to balance the interest of parties and end the litigation, we allow the relief of Rs. 6 lakhs to assessee and confirm the remaining amount of Rs. 4 lakhs. Considering the submissions made by the as ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... income u/s 139(1) on 24.9.2016 declaring total income at Rs. 40,46,550/-. A search & seizure action u/s 132 of the I.T. Act was conducted on the assessee as part of the searches conducted on M/s. Skill Promoters Pvt. Ltd Group and others on 22.10.2019. The case was subsequently centralized and notice u/s 153A dated 2.2.201 for the A.Y 2016-17 was issued to the assessee, to which the assessee filed its return of income on 1.3.2021. Thereafter, statutory notices u/s 143(2) and 142(1) were issued and served on the assessee to which the A.R of the assessee appeared and filed the requisite details. 3.1 During the post search proceedings, the assessee was asked to explain the transaction in respect of the seized material at pages 28 and 29 of A ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... that the assessee had been an income tax assessee for the past three years and had filed income tax returns declaring more than Rs. 10 lakhs, for the relevant assessment years prior to A.Y. 2016-17. Ld.AR for the assessee further submitted that the said contention was also placed before the ld. CIT(A). 7. On the other hand, ld. DR supported the orders of lower authorities. 8. We have heard the rival submissions and perused the material on record. In the present case, we noted that certain material was seized during the search and seizure operation conducted in the assessee's case and upon reviewing page numbers 28 and 29 of the seized material vide Annexure-A/BN/RES/01, it was found that assessee had paid Rs. 9,00,000/- and Rs. 1,00,000/- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... provided by the assessee, it is plausible that these payments were made as part of the settlement of a dispute regarding land in Sy. No. 10 of Guttala Begumpet, and not as income belonging to the assessee. It is worth noting that the assessee has been a regular filer of income tax returns for the past three years and has declared income exceeding Rs. 10 lakhs for the relevant assessment years prior to the current one, which supports the assessee's claim that the undisclosed income of Rs. 10 lakhs can be explained from past accumulations or savings and we do not find assessee's contention as an after thought. Since the assessee failed to provide sufficient evidence before the Assessing Officer and he had only raised the plea before the l ..... X X X X Extracts X X X X X X X X Extracts X X X X
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