CIT v. Sonal Construction

VISHWANATH AGGARWAL,DELHI vs. THE ADDL. CIT, CENTRAL RANGE-05, DELHI

The appeals of the assessee are allowed and the penalty is deleted

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmaitas No.611 To 618/Del/2022 Assessment Years: 2010-11, 2012-13, 2011-12,2013-14, 2010-11, 2011-12, 2012-13 & 2013-14 Vishwanath Aggarwal, Vs Addl. Cit, House No.98, Block C-2, Range-05, Janakpuri, Delhi. New Delhi – 110 058. Pan: Abxpa4825B (Appellant) (Respondent) Assessee By : Shri Sudesh Garg, Advocate & Shri Prince Bansal, Ca Revenue By : Ms Sapna Bhatia, Cit-Dr Date Of Hearing : 04.07.2024 Date Of Pronouncement : .07.2024 Order Per Anubhav Sharma, Jm: These Are Appeals Preferred By The Assessee Against The Orders Of The Commissioner Of Income Tax (Appeals) (Hereinafter Referred To As Ld. First Appellate Authority Or ‘The Ld. Faa’ For Short) In Appeals Filed Before Him Against The Penalty Orders Of The Ld. Assessing Officer (Hereinafter Referred To As The Ld. Ao, For Short). Further Details Of The Penalty Orders Of The Lower Authorities Are As Under:-

…ssee in the proceedings u/s 153A or present penalty proceedings. This contention of the assessee is also devoid of any merit. In this regard, a reference is made to the decision of Hon’ble Delhi High Court in the case of CIT Vs Sonal Constructions reported in 359 ITR 532 (Delhi)[2013] wherein Hon’ble High Court has held that “Where during search certain documents were seized from possession of a partner of assessee-firm, merely because partners were not examined by Assessing Officer at time of assessment, it could not be stated that no reliance could be placed on seized materials for purposes of making additions”…

VISHWANATH AGGARWAL,DELHI vs. THE ADDL. CIT, CENTRAL RANGE-05, DELHI

The appeals of the assessee are allowed and the penalty is deleted

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmaitas No.611 To 618/Del/2022 Assessment Years: 2010-11, 2012-13, 2011-12,2013-14, 2010-11, 2011-12, 2012-13 & 2013-14 Vishwanath Aggarwal, Vs Addl. Cit, House No.98, Block C-2, Range-05, Janakpuri, Delhi. New Delhi – 110 058. Pan: Abxpa4825B (Appellant) (Respondent) Assessee By : Shri Sudesh Garg, Advocate & Shri Prince Bansal, Ca Revenue By : Ms Sapna Bhatia, Cit-Dr Date Of Hearing : 04.07.2024 Date Of Pronouncement : .07.2024 Order Per Anubhav Sharma, Jm: These Are Appeals Preferred By The Assessee Against The Orders Of The Commissioner Of Income Tax (Appeals) (Hereinafter Referred To As Ld. First Appellate Authority Or ‘The Ld. Faa’ For Short) In Appeals Filed Before Him Against The Penalty Orders Of The Ld. Assessing Officer (Hereinafter Referred To As The Ld. Ao, For Short). Further Details Of The Penalty Orders Of The Lower Authorities Are As Under:-

…ssee in the proceedings u/s 153A or present penalty proceedings. This contention of the assessee is also devoid of any merit. In this regard, a reference is made to the decision of Hon’ble Delhi High Court in the case of CIT Vs Sonal Constructions reported in 359 ITR 532 (Delhi)[2013] wherein Hon’ble High Court has held that “Where during search certain documents were seized from possession of a partner of assessee-firm, merely because partners were not examined by Assessing Officer at time of assessment, it could not be stated that no reliance could be placed on seized materials for purposes of making additions”…

VISHWANATH AGGARWAL ,DELHI vs. THE ADDL. CIT, CENTRAL RANGE-05, DELHI

The appeals of the assessee are allowed and the penalty is deleted

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmaitas No.611 To 618/Del/2022 Assessment Years: 2010-11, 2012-13, 2011-12,2013-14, 2010-11, 2011-12, 2012-13 & 2013-14 Vishwanath Aggarwal, Vs Addl. Cit, House No.98, Block C-2, Range-05, Janakpuri, Delhi. New Delhi – 110 058. Pan: Abxpa4825B (Appellant) (Respondent) Assessee By : Shri Sudesh Garg, Advocate & Shri Prince Bansal, Ca Revenue By : Ms Sapna Bhatia, Cit-Dr Date Of Hearing : 04.07.2024 Date Of Pronouncement : .07.2024 Order Per Anubhav Sharma, Jm: These Are Appeals Preferred By The Assessee Against The Orders Of The Commissioner Of Income Tax (Appeals) (Hereinafter Referred To As Ld. First Appellate Authority Or ‘The Ld. Faa’ For Short) In Appeals Filed Before Him Against The Penalty Orders Of The Ld. Assessing Officer (Hereinafter Referred To As The Ld. Ao, For Short). Further Details Of The Penalty Orders Of The Lower Authorities Are As Under:-

…ssee in the proceedings u/s 153A or present penalty proceedings. This contention of the assessee is also devoid of any merit. In this regard, a reference is made to the decision of Hon’ble Delhi High Court in the case of CIT Vs Sonal Constructions reported in 359 ITR 532 (Delhi)[2013] wherein Hon’ble High Court has held that “Where during search certain documents were seized from possession of a partner of assessee-firm, merely because partners were not examined by Assessing Officer at time of assessment, it could not be stated that no reliance could be placed on seized materials for purposes of making additions”…

VISHWANATH AGGARWAL,DELHI vs. THE ADDL. CIT, CENTRAL RANGE-05, DELHI

The appeals of the assessee are allowed and the penalty is deleted

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmaitas No.611 To 618/Del/2022 Assessment Years: 2010-11, 2012-13, 2011-12,2013-14, 2010-11, 2011-12, 2012-13 & 2013-14 Vishwanath Aggarwal, Vs Addl. Cit, House No.98, Block C-2, Range-05, Janakpuri, Delhi. New Delhi – 110 058. Pan: Abxpa4825B (Appellant) (Respondent) Assessee By : Shri Sudesh Garg, Advocate & Shri Prince Bansal, Ca Revenue By : Ms Sapna Bhatia, Cit-Dr Date Of Hearing : 04.07.2024 Date Of Pronouncement : .07.2024 Order Per Anubhav Sharma, Jm: These Are Appeals Preferred By The Assessee Against The Orders Of The Commissioner Of Income Tax (Appeals) (Hereinafter Referred To As Ld. First Appellate Authority Or ‘The Ld. Faa’ For Short) In Appeals Filed Before Him Against The Penalty Orders Of The Ld. Assessing Officer (Hereinafter Referred To As The Ld. Ao, For Short). Further Details Of The Penalty Orders Of The Lower Authorities Are As Under:-

…ssee in the proceedings u/s 153A or present penalty proceedings. This contention of the assessee is also devoid of any merit. In this regard, a reference is made to the decision of Hon’ble Delhi High Court in the case of CIT Vs Sonal Constructions reported in 359 ITR 532 (Delhi)[2013] wherein Hon’ble High Court has held that “Where during search certain documents were seized from possession of a partner of assessee-firm, merely because partners were not examined by Assessing Officer at time of assessment, it could not be stated that no reliance could be placed on seized materials for purposes of making additions”…

VISHWANATH AGGARWAL,DELHI vs. THE ADDL. CIT, CENTRAL RANGE-05, DELHI

The appeals of the assessee are allowed and the penalty is deleted

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmaitas No.611 To 618/Del/2022 Assessment Years: 2010-11, 2012-13, 2011-12,2013-14, 2010-11, 2011-12, 2012-13 & 2013-14 Vishwanath Aggarwal, Vs Addl. Cit, House No.98, Block C-2, Range-05, Janakpuri, Delhi. New Delhi – 110 058. Pan: Abxpa4825B (Appellant) (Respondent) Assessee By : Shri Sudesh Garg, Advocate & Shri Prince Bansal, Ca Revenue By : Ms Sapna Bhatia, Cit-Dr Date Of Hearing : 04.07.2024 Date Of Pronouncement : .07.2024 Order Per Anubhav Sharma, Jm: These Are Appeals Preferred By The Assessee Against The Orders Of The Commissioner Of Income Tax (Appeals) (Hereinafter Referred To As Ld. First Appellate Authority Or ‘The Ld. Faa’ For Short) In Appeals Filed Before Him Against The Penalty Orders Of The Ld. Assessing Officer (Hereinafter Referred To As The Ld. Ao, For Short). Further Details Of The Penalty Orders Of The Lower Authorities Are As Under:-

…ssee in the proceedings u/s 153A or present penalty proceedings. This contention of the assessee is also devoid of any merit. In this regard, a reference is made to the decision of Hon’ble Delhi High Court in the case of CIT Vs Sonal Constructions reported in 359 ITR 532 (Delhi)[2013] wherein Hon’ble High Court has held that “Where during search certain documents were seized from possession of a partner of assessee-firm, merely because partners were not examined by Assessing Officer at time of assessment, it could not be stated that no reliance could be placed on seized materials for purposes of making additions”…

VISHWANATH AGGARWAL,DELHI vs. THE ADDL. CIT, CENTRAL RANGE-05, DELHI

The appeals of the assessee are allowed and the penalty is deleted

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmaitas No.611 To 618/Del/2022 Assessment Years: 2010-11, 2012-13, 2011-12,2013-14, 2010-11, 2011-12, 2012-13 & 2013-14 Vishwanath Aggarwal, Vs Addl. Cit, House No.98, Block C-2, Range-05, Janakpuri, Delhi. New Delhi – 110 058. Pan: Abxpa4825B (Appellant) (Respondent) Assessee By : Shri Sudesh Garg, Advocate & Shri Prince Bansal, Ca Revenue By : Ms Sapna Bhatia, Cit-Dr Date Of Hearing : 04.07.2024 Date Of Pronouncement : .07.2024 Order Per Anubhav Sharma, Jm: These Are Appeals Preferred By The Assessee Against The Orders Of The Commissioner Of Income Tax (Appeals) (Hereinafter Referred To As Ld. First Appellate Authority Or ‘The Ld. Faa’ For Short) In Appeals Filed Before Him Against The Penalty Orders Of The Ld. Assessing Officer (Hereinafter Referred To As The Ld. Ao, For Short). Further Details Of The Penalty Orders Of The Lower Authorities Are As Under:-

…ssee in the proceedings u/s 153A or present penalty proceedings. This contention of the assessee is also devoid of any merit. In this regard, a reference is made to the decision of Hon’ble Delhi High Court in the case of CIT Vs Sonal Constructions reported in 359 ITR 532 (Delhi)[2013] wherein Hon’ble High Court has held that “Where during search certain documents were seized from possession of a partner of assessee-firm, merely because partners were not examined by Assessing Officer at time of assessment, it could not be stated that no reliance could be placed on seized materials for purposes of making additions”…

VISHWANATH AGGARWAL,DELHI vs. THE ADDL. CIT, CENTRAL RANGE-05, DELHI

The appeals of the assessee are allowed and the penalty is deleted

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmaitas No.611 To 618/Del/2022 Assessment Years: 2010-11, 2012-13, 2011-12,2013-14, 2010-11, 2011-12, 2012-13 & 2013-14 Vishwanath Aggarwal, Vs Addl. Cit, House No.98, Block C-2, Range-05, Janakpuri, Delhi. New Delhi – 110 058. Pan: Abxpa4825B (Appellant) (Respondent) Assessee By : Shri Sudesh Garg, Advocate & Shri Prince Bansal, Ca Revenue By : Ms Sapna Bhatia, Cit-Dr Date Of Hearing : 04.07.2024 Date Of Pronouncement : .07.2024 Order Per Anubhav Sharma, Jm: These Are Appeals Preferred By The Assessee Against The Orders Of The Commissioner Of Income Tax (Appeals) (Hereinafter Referred To As Ld. First Appellate Authority Or ‘The Ld. Faa’ For Short) In Appeals Filed Before Him Against The Penalty Orders Of The Ld. Assessing Officer (Hereinafter Referred To As The Ld. Ao, For Short). Further Details Of The Penalty Orders Of The Lower Authorities Are As Under:-

…ssee in the proceedings u/s 153A or present penalty proceedings. This contention of the assessee is also devoid of any merit. In this regard, a reference is made to the decision of Hon’ble Delhi High Court in the case of CIT Vs Sonal Constructions reported in 359 ITR 532 (Delhi)[2013] wherein Hon’ble High Court has held that “Where during search certain documents were seized from possession of a partner of assessee-firm, merely because partners were not examined by Assessing Officer at time of assessment, it could not be stated that no reliance could be placed on seized materials for purposes of making additions”…

VISHWANATH AGGARWAL ,DELHI vs. THE ADDL. CIT, CENTRAL RANGE-05, DELHI

The appeals of the assessee are allowed and the penalty is deleted

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmaitas No.611 To 618/Del/2022 Assessment Years: 2010-11, 2012-13, 2011-12,2013-14, 2010-11, 2011-12, 2012-13 & 2013-14 Vishwanath Aggarwal, Vs Addl. Cit, House No.98, Block C-2, Range-05, Janakpuri, Delhi. New Delhi – 110 058. Pan: Abxpa4825B (Appellant) (Respondent) Assessee By : Shri Sudesh Garg, Advocate & Shri Prince Bansal, Ca Revenue By : Ms Sapna Bhatia, Cit-Dr Date Of Hearing : 04.07.2024 Date Of Pronouncement : .07.2024 Order Per Anubhav Sharma, Jm: These Are Appeals Preferred By The Assessee Against The Orders Of The Commissioner Of Income Tax (Appeals) (Hereinafter Referred To As Ld. First Appellate Authority Or ‘The Ld. Faa’ For Short) In Appeals Filed Before Him Against The Penalty Orders Of The Ld. Assessing Officer (Hereinafter Referred To As The Ld. Ao, For Short). Further Details Of The Penalty Orders Of The Lower Authorities Are As Under:-

…ssee in the proceedings u/s 153A or present penalty proceedings. This contention of the assessee is also devoid of any merit. In this regard, a reference is made to the decision of Hon’ble Delhi High Court in the case of CIT Vs Sonal Constructions reported in 359 ITR 532 (Delhi)[2013] wherein Hon’ble High Court has held that “Where during search certain documents were seized from possession of a partner of assessee-firm, merely because partners were not examined by Assessing Officer at time of assessment, it could not be stated that no reliance could be placed on seized materials for purposes of making additions”…

ACIT, CENTRAL CIRCLE-04, NEW DELHI vs. VISHNU KUMAR GARG, FARIDABAD

Bench: Shri R.K. Panda & Ms. Suchitra Kamble

…as undisclosed income of assessee. He submitted that unless telescoping is given, it will amount to double addition. Learned Counsel for the Assessee also relied on the decision of Hon’ble Delhi High Court in the case of CIT vs., Sonal Construction [2013] 359 ITR 532 (Del.) and the decision of Hon’ble Supreme Court in the case of Anantharan Veerasinghaiah & Co. vs., CIT [1980] 123 ITR 457 (SC). 9. The Ld. D.R. on the other hand relied on the order of the Ld. CIT(A) and submitted that assessee could not substantiate with evidence to the satisfaction of the A.O. or the Ld. CIT(A) regarding the amount paid t…

ACIT, CENTRAL CIRCLE-04, NEW DELHI vs. VISHNU KUMAR GARG, FARIDABAD

Bench: Shri R.K. Panda & Ms. Suchitra Kamble

…as undisclosed income of assessee. He submitted that unless telescoping is given, it will amount to double addition. Learned Counsel for the Assessee also relied on the decision of Hon’ble Delhi High Court in the case of CIT vs., Sonal Construction [2013] 359 ITR 532 (Del.) and the decision of Hon’ble Supreme Court in the case of Anantharan Veerasinghaiah & Co. vs., CIT [1980] 123 ITR 457 (SC). 9. The Ld. D.R. on the other hand relied on the order of the Ld. CIT(A) and submitted that assessee could not substantiate with evidence to the satisfaction of the A.O. or the Ld. CIT(A) regarding the amount paid t…

RR CARWELL PVT LTD,NEW DELHI vs. DCIT CENTRAL CIRCLE-4, NEW DELHI

In the result, appeals filed by the assessee for AY

Bench: Shri R.K. Panda & Ms. Suchitra Kamble

…lescoping of above expenditure out of the income sustained out of bogus purchases finds merit. The Hon’ble Delhi High Court in the case of CIT vs. Sonal 45 ITA.Nos.9153 to 9158/Del./2019 M/s. R R Carwell Pvt. Ltd., New Delhi. Construction reported in [2013] 359 ITR 532 (Del.) has accepted the theory of benefit of telescoping. We, therefore, held that the assessee is entitled to the benefit of telescoping of the addition of unexplained expenditure of Rs.4,22,975/- out of the additions mere on account of bogus purchases, etc. The ground of appeal no.7 is accordingly partly allowed. 13. Ground of appeal no.9 to…

RR CARWELL PVT LTD,NEW DELHI vs. DCIT CENTRAL CIRCLE-4, NEW DELHI

In the result, appeals filed by the assessee for AY

Bench: Shri R.K. Panda & Ms. Suchitra Kamble

…lescoping of above expenditure out of the income sustained out of bogus purchases finds merit. The Hon’ble Delhi High Court in the case of CIT vs. Sonal 45 ITA.Nos.9153 to 9158/Del./2019 M/s. R R Carwell Pvt. Ltd., New Delhi. Construction reported in [2013] 359 ITR 532 (Del.) has accepted the theory of benefit of telescoping. We, therefore, held that the assessee is entitled to the benefit of telescoping of the addition of unexplained expenditure of Rs.4,22,975/- out of the additions mere on account of bogus purchases, etc. The ground of appeal no.7 is accordingly partly allowed. 13. Ground of appeal no.9 to…

RR CARWELL PVT LTD,NEW DELHI vs. DCIT CENTRAL CIRCLE-4, NEW DELHI

In the result, appeals filed by the assessee for AY

Bench: Shri R.K. Panda & Ms. Suchitra Kamble

…lescoping of above expenditure out of the income sustained out of bogus purchases finds merit. The Hon’ble Delhi High Court in the case of CIT vs. Sonal 45 ITA.Nos.9153 to 9158/Del./2019 M/s. R R Carwell Pvt. Ltd., New Delhi. Construction reported in [2013] 359 ITR 532 (Del.) has accepted the theory of benefit of telescoping. We, therefore, held that the assessee is entitled to the benefit of telescoping of the addition of unexplained expenditure of Rs.4,22,975/- out of the additions mere on account of bogus purchases, etc. The ground of appeal no.7 is accordingly partly allowed. 13. Ground of appeal no.9 to…

RR CARWELL PVT LTD,NEW DELHI vs. DCIT CENTRAL CIRCLE-4, NEW DELHI

In the result, appeals filed by the assessee for AY

Bench: Shri R.K. Panda & Ms. Suchitra Kamble

…lescoping of above expenditure out of the income sustained out of bogus purchases finds merit. The Hon’ble Delhi High Court in the case of CIT vs. Sonal 45 ITA.Nos.9153 to 9158/Del./2019 M/s. R R Carwell Pvt. Ltd., New Delhi. Construction reported in [2013] 359 ITR 532 (Del.) has accepted the theory of benefit of telescoping. We, therefore, held that the assessee is entitled to the benefit of telescoping of the addition of unexplained expenditure of Rs.4,22,975/- out of the additions mere on account of bogus purchases, etc. The ground of appeal no.7 is accordingly partly allowed. 13. Ground of appeal no.9 to…

RR CARWELL PVT LTD,NEW DELHI vs. DCIT CENTRAL CIRCLE-4, NEW DELHI

In the result, appeals filed by the assessee for AY

Bench: Shri R.K. Panda & Ms. Suchitra Kamble

…lescoping of above expenditure out of the income sustained out of bogus purchases finds merit. The Hon’ble Delhi High Court in the case of CIT vs. Sonal 45 ITA.Nos.9153 to 9158/Del./2019 M/s. R R Carwell Pvt. Ltd., New Delhi. Construction reported in [2013] 359 ITR 532 (Del.) has accepted the theory of benefit of telescoping. We, therefore, held that the assessee is entitled to the benefit of telescoping of the addition of unexplained expenditure of Rs.4,22,975/- out of the additions mere on account of bogus purchases, etc. The ground of appeal no.7 is accordingly partly allowed. 13. Ground of appeal no.9 to…

RR CARWELL PVT LTD,NEW DELHI vs. DCIT CENTRAL CIRCLE-4, NEW DELHI

In the result, appeals filed by the assessee for AY

Bench: Shri R.K. Panda & Ms. Suchitra Kamble

…lescoping of above expenditure out of the income sustained out of bogus purchases finds merit. The Hon’ble Delhi High Court in the case of CIT vs. Sonal 45 ITA.Nos.9153 to 9158/Del./2019 M/s. R R Carwell Pvt. Ltd., New Delhi. Construction reported in [2013] 359 ITR 532 (Del.) has accepted the theory of benefit of telescoping. We, therefore, held that the assessee is entitled to the benefit of telescoping of the addition of unexplained expenditure of Rs.4,22,975/- out of the additions mere on account of bogus purchases, etc. The ground of appeal no.7 is accordingly partly allowed. 13. Ground of appeal no.9 to…

VISHNU KUMAR GARG,FARIDABAD vs. DCIT CENTRAL CIRCLE-4, NEW DELHI

Bench: Shri R.K. Panda & Ms. Suchitra Kamble

…as undisclosed income of assessee. He submitted that unless telescoping is given, it will amount to double addition. Learned Counsel for the Assessee also relied on the decision of Hon’ble Delhi High Court in the case of CIT vs., Sonal Construction [2013] 359 ITR 532 (Del.) and the decision of Hon’ble Supreme Court in the case of Anantharan Veerasinghaiah & Co. vs., CIT [1980] 123 ITR 457 (SC). 9. The Ld. D.R. on the other hand relied on the order of the Ld. CIT(A) and submitted that assessee could not substantiate with evidence to the satisfaction of the A.O. or the Ld. CIT(A) regarding the amount paid t…

VISHNU KUMAR GARG,FARIDABAD vs. DCIT CENTRAL CIRCLE-4, NEW DELHI

Bench: Shri R.K. Panda & Ms. Suchitra Kamble

…as undisclosed income of assessee. He submitted that unless telescoping is given, it will amount to double addition. Learned Counsel for the Assessee also relied on the decision of Hon’ble Delhi High Court in the case of CIT vs., Sonal Construction [2013] 359 ITR 532 (Del.) and the decision of Hon’ble Supreme Court in the case of Anantharan Veerasinghaiah & Co. vs., CIT [1980] 123 ITR 457 (SC). 9. The Ld. D.R. on the other hand relied on the order of the Ld. CIT(A) and submitted that assessee could not substantiate with evidence to the satisfaction of the A.O. or the Ld. CIT(A) regarding the amount paid t…

VISHNU KUMAR GARG,FARIDABAD vs. DCIT CENTRAL CIRCLE-4, NEW DELHI

Bench: Shri R.K. Panda & Ms. Suchitra Kamble

…as undisclosed income of assessee. He submitted that unless telescoping is given, it will amount to double addition. Learned Counsel for the Assessee also relied on the decision of Hon’ble Delhi High Court in the case of CIT vs., Sonal Construction [2013] 359 ITR 532 (Del.) and the decision of Hon’ble Supreme Court in the case of Anantharan Veerasinghaiah & Co. vs., CIT [1980] 123 ITR 457 (SC). 9. The Ld. D.R. on the other hand relied on the order of the Ld. CIT(A) and submitted that assessee could not substantiate with evidence to the satisfaction of the A.O. or the Ld. CIT(A) regarding the amount paid t…

VISHNU KUMAR GARG,FARIDABAD vs. DCIT CENTRAL CIRCLE-4, NEW DELHI

Bench: Shri R.K. Panda & Ms. Suchitra Kamble

…as undisclosed income of assessee. He submitted that unless telescoping is given, it will amount to double addition. Learned Counsel for the Assessee also relied on the decision of Hon’ble Delhi High Court in the case of CIT vs., Sonal Construction [2013] 359 ITR 532 (Del.) and the decision of Hon’ble Supreme Court in the case of Anantharan Veerasinghaiah & Co. vs., CIT [1980] 123 ITR 457 (SC). 9. The Ld. D.R. on the other hand relied on the order of the Ld. CIT(A) and submitted that assessee could not substantiate with evidence to the satisfaction of the A.O. or the Ld. CIT(A) regarding the amount paid t…