9911796707
TMI Blog2024 (5) TMI 1474X X X X Extracts X X X X X X X X Extracts X X X X ..... arious transactions which fell for scrutiny were not undertaken in the accounts of the assessee. HELD THAT:- This argument essentially requires us to delve into facts and which do not even appear to have been either raised or urged before the ITAT. In any case, such a course would not be merited bearing in mind the limited scope of this appeal and which stands confined to the consideration of a su ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ng, in the first stance, whether or not the appellant is partly or fully an owner or beneficiary in the bank accounts reported to have cash deposits? (ii) Whether as per Article 265 of Constitution the appellant can be taxed based on consent without there being any liability as per law in as much as the appellant is not having any ownership or beneficial interest in the bank accounts in which ther ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... accounts, issued no notice/conducted no hearing/asked for no explanation/gave no opportunity to explain about deposit of Rs 13,38,500/- in the account of Mr. Siddharth Bansal, rejected revised return filed on 18.12.2015 prior to finalization of assessment on 30.03.2016, referred to or called for none of the documents mentioned in Annexure-A/5, Annexure-A/6, Annexure-A/7 Annexure- A/8 and Annexure ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nt of intentional, deliberate and knowingly erring in favour of revenue ? (vii) The related substantial question of law that arises is whether an admission of filing revised return and deposit of related tax to buy peace can be taken as an admission by free consent and whether the tax imposed on the appellate in the circumstances of the case is not illegal and unconstitutional as per Article 265 o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... uires us to delve into facts and which do not even appear to have been either raised or urged before the ITAT. In any case, such a course would not be merited bearing in mind the limited scope of this appeal and which stands confined to the consideration of a substantial question of law. 4. In view of the aforesaid, we find no merit in the appeal. Consequently, the appeal fails and shall stand dis ..... X X X X Extracts X X X X X X X X Extracts X X X X
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