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TMI Blog2009 (11) TMI 38X X X X Extracts X X X X X X X X Extracts X X X X ..... g officer on the basis of material which is required to be considered for the purpose of assessment and ordinarily not on the basis of the statement of third party unless and until there is a material to corroborate that statement. - . The mere fact that one of the accomplish tendered inconsistent statement that itself cannot be treated as having resulted in an irrebuttable presumption against the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ch "I" New Delhi in IT (SS) No. 381/Del/2005 dated 31.8.2007 for the block period 1997-98 to 2003-04, proposing to raise the following substantial questions of law:- "Whether on the facts and in the circumstances of the case, the finding recorded by the Ld. I.T.A.T. are perverse and contrary to evidence and statements of parties on record ? Whether on the facts and in the circumstances of t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . At the same time it is clear from a reading of Section 69 that before the amount is said to be unexplained and is added as income of the assessee, opportunity should be provided to the assessee to explain the source. The assessee's income is to be assessed by the assessing officer on the basis of material which is required to be considered for the purpose of assessment and ordinarily not on the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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