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TMI Blog2025 (3) TMI 1232X X X X Extracts X X X X X X X X Extracts X X X X ..... Respondent: Mr Suresh Kumar,. PC:- 1. Heard Mr. Jhaveri for the Appellant and Mr. Kumar for the Respondent. This Appeal relates to the assessment year 2006-07. 2. Admittedly, a search was carried out on Bharati Vidyapeeth and the premises owned by the Assessee. During the search Rs. 3,14,83,870/-was found with the Assessee. The appellant offered this amount for tax in A.Y. 2005-06 and 2006-0 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on the basis of conjectures & surmises, that the cash found during the search did not include the amount of Rs. 2,00,50,000/-, added in the hands of the Appellant. (b) Whether on the facts and in the circumstances of the case and in law the Hon'ble Tribunal misdirected itself by sustaining the addition of Rs. 2,00,50,000/- without giving a clear finding that the said amount was separate & diffe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n reached could be said to suffer from perversity. He also submitted that the three authorities did not adequately consider vital documents. Mr Jhaveri has advanced no other submissions. 6. Upon evaluating Mr. Jhaveri's submissions, we are unconvinced that this Appeal gives rise to any question of law, much less any substantial question of law. Upon a detailed evaluation of the material on record ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the admission, he would refund the said amount. Based on such statements and the material on record, the three authorities concluded that the Assessee could not co-relate the amount of cash seized with the amount noted in the documents. 8. The ITAT also referred the Assessee's statement about using code figures regarding his 'consultancy fees'. The Assessee accepted all these documents. In these ..... X X X X Extracts X X X X X X X X Extracts X X X X
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