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“undisclosed income”

Search & SeizureSection 153ASection 153A9,092 judgments

The decision most relied on for undisclosed income is CIT v. Kabul Chawla (380 ITR 573), cited in 3,235 judgments on BharatTax.

Leading authorities on undisclosed income

CIT v. Kabul Chawla
380 ITR 573 · 2016 · High Court
3,235
citing judgments

In a search assessment under Section 153A, additions can only be made for completed or non-abated assessment years if incriminating material relevant to those years is found during the search, although notice under Section 153A(1) is mandatorily issued for six assessment years preceding the search.

CIT v. Simit P. Sheth
356 ITR 451 · 2013 · High Court
1,465
citing judgments

Additions for alleged bogus purchases should be restricted to the profit element, not the entire turnover. The profit element is often estimated at 12.5% of the purported bogus purchases.

Commissioner of Income Tax v. Harjeev Aggarwal
290 CTR 263 · 2016 · High Court
583
citing judgments

Assessment based solely on a statement recorded under Section 132(4) of the Income Tax Act requires the statement to be relatable to incriminating material or evidence found during the search, especially when considering Section 158BB(1) which restricts computation of undisclosed income to evidence found during search.

CIT v. Anil Kumar Bhatia
352 ITR 493 · 2013 · High Court
537
citing judgments

Section 153A can be invoked to reassess income for all years under consideration prior to a search, even if returns for those years were processed under Section 143(1)(a). The Assessing Officer has the power to reassess total income in such cases without fetters.

CIT v. P. Mohanakala
291 ITR 278 · 2007 · Supreme Court
525
citing judgments

The Supreme Court emphasized that in the absence of concrete rebuttal by the assessee, circumstantial evidence holds significant weight, applying the doctrine of preponderance of probability, particularly when assessing undisclosed income or unexplained cash credits.

Society v. UOI
394 ITR 220 · 2017 · Supreme Court
493
citing judgments

Uncorroborated loose papers or documents found during a search operation have no evidentiary value and cannot be the sole basis for determining undisclosed income. Additions based on such material require independent evidence to establish trustworthiness and a direct link to the assessee.

CIT v. President Industries
258 ITR 654 · 2002 · High Court
471
citing judgments

When books of account are rejected and unaccounted sales or receipts are discovered, the income addition is restricted to the net profit element embedded in these undisclosed transactions, not the entire sale proceeds or receipts, especially if corresponding purchases are not proven to be outside the books.

CIT v. Gurinder Singh Bawa
386 ITR 483 · 2016 · High Court
416
citing judgments

If no incriminating material is found during a search operation regarding a particular issue, then no addition can be made concerning that issue in an assessment under section 153A of the Income-tax Act.

Judgments citing undisclosed income

Sh. Sanjay Godha, Jaipur vs. ACIT, Circle-1, Jaipur

In the result, the appeal of the assessee is allowed

ITA 539/JPR/2024[2017-18]Status: DisposedITAT Jaipur29 Aug 2024AY 2017-18

Bench: This Tribunal. The Said Order Of The Ld. Cit(A) Arises Because The Assessee Preferred An Appeal Before Him Against The Order Dated 20/11/2019 Passed Under Section 143(3) Of The Income Tax Act, By Acit, Circle-01, Jaipur.

For Appellant: Sh. P. C. Parwal, FCAFor Respondent: Sh. Anoop Singh, Addl. CIT
Section 115BSection 142(1)Section 143(2)Section 143(3)Section 69A

order by the ld. AO he has made an addition of Rs. 55,30,000/- the amount deposited into the bank account as undisclosed income of the assessee as per section 69A of the Act. 4. Aggrieved from the above order of the assessing officer, assessee preferred and an appeal

Brij Bihari Agrawal, Jaipur vs. The Assistant Commissioner of Income Tax Central Circle - 1, Jaipur

In the result the appeal of the assessee is allowed

ITA 737/JPR/2023[2013-14]Status: DisposedITAT Jaipur29 Aug 2024AY 2013-14
For Appellant: Shri Tarun Mittal (C.A)
Section 142(1)Section 147Section 148Section 153ASection 153C

sheet found with an employee of the Maverick group, by alleging the same as containing details of interest paid by the assessee out of undisclosed income, without appreciating the explanation/ documents filed by the assessee. The addition so confirmed deserves to be deleted. 3. On the facts ... carried out on Maverick group, the assessee had paid interest to various money lending companies out of undisclosed incomeé& is liable to considered as undisclosed income of the assesse and the income of Rs. 1,76,342/- has escaped assessment within the meaning

Leo Realtors, Mumbai vs. DCIT, Central Circle-6(2), Mumbai

In the result, appeal of the assessee is allowed

ITA 3677/MUM/2024[2009-10]Status: DisposedITAT Mumbai29 Aug 2024AY 2009-10

Bench: Us The Assessee Has Raised Following Grounds:- “1) That On The Facts & Circumstances Of The Case & In Law, The Ld. Cit (A) Erred In Confirming The Order Passed By The Ld. Ao

Section 131Section 143(1)Section 143(3)Section 147Section 148

cash has been No. received 1 Bogus loss on sale 55,00,000/- of shares Total 55,00,000/- The above mentioned amount represents undisclosed income of the assessee for the relevant year" 4. Thus, the entire premise for reopening is that assessee has entered into transaction for bogus loss ... Realtors as evident from the ledger A/c of M/s. BHOOMI CONSTRUCTION (BRIZE A/C) pertaining to A.Y. 2009-10 is the 5 M/s. Leo Realtors undisclosed income of the assessee received in cash for that year which is not recorded in the regular books of account. 5.3 The ledger account

Virendrakumar Brijratan Mohatta, Mumbai vs. JCIT-19(2), Mumbai

In the result, the appeal by the assessee is allowed for statistical purposes

ITA 3634/MUM/2024[1999-2000]Status: DisposedITAT Mumbai29 Aug 2024AY 1999-2000

Bench: Ms. Padmavathy S & Shri Sandeep Singh Karhail

For Appellant: Shri Ravikanth PathakFor Respondent: Shri Surendra Meena, Sr. DR
Section 143(3)Section 147Section 250Section 271(1)(c)Section 274Section 69A

section 147 of the Act, the AO made an addition of Rs.73,50,000 under section 69A of the Act being undisclosed income of the assessee from an undisclosed bank account in HSBC Bank, Geneva, Switzerland. In the meanwhile, notice under section 274 r/w section

Pragya Gupta, Meerut vs. ITO, Ward-(1)(2)(1), Meerut

In the result, the appeal of the assessee is allowed

ITA 234/DEL/2024[2017-18]Status: DisposedITAT Delhi29 Aug 2024AY 2017-18

Bench: Shri M. Balaganesh & Shri Vimal Kumarpragya Gupta, Vs. Ito, W/O. Gaurav Gupta, 224, Ward-1(2)(1), Madhuban Colony Baghpat Meerut Road, Meerut, Uttar Pradesh (Appellant) (Respondent) Pan:Aivpg3134C

For Appellant: Shri Rohit Agarwal, CAFor Respondent: Shri Vivek Vardhan, Sr. DR
Section 143(3)Section 271ASection 44ASection 69A

same as income u/s 69A of the Act. While doing so, he found that the assessee had declared an amount of ₹10,00,000/- undisclosed income in the form of cash under Pradhan Mantri Garib Kalyan Scheme 2016 on 27.03.2017, for which the ld AO gave credit and accordingly proceeded ... treat the sum of Rs. 88,42,038/- as undisclosed income u/s 69A of the Act. The ld AO in para 4 page 25 of his order also observed the correctness and completeness of the books of account is not established and accordingly invoked section

Deputy Commissioner of Income Tax, Central Circle-15, New Delhi vs. Deepti Agrawal, New Delhi

In the result, both the appeals of the assessee are allowed

ITA 224/DEL/2024[2016-17]Status: DisposedITAT Delhi29 Aug 2024AY 2016-17

Bench: Sh. Saktijit Dey & Sh. M. Balaganeshdcit Vs. Deepti Agrawal Central Circle – 15 1-A, Maharaja Lal Lane, New Delhi Civil Lines, New Delhi-110 054 Pan No. Aampa 0573 C (Appellant) (Respondent) & Co No. 48/Del/2024 (In Ita No.224/Del/2024) (Assessment Year : 2016-17) Deepti Agrawal Vs. Dcit 1-A, Maharaja Lal Lane, Central Circle – 15 Civil Lines, New Delhi New Delhi-110 054 Pan No. Aampa 0573 C (Appellant) (Respondent)

Section 10(38)Section 147Section 69C

transaction by unscrupulous elements. Keeping in view you are requested to explain why not gain (LTCG) amounting to Rs. 30305713/- to be assessed as undisclosed income while considering as escape assessment.” In para 5, ld. AO has again stated as - “Therefore, you are asked to show cause

DCIT, CC-20, Delhi vs. Rajiv Agarwal, Delhi

In the result, the appeals of the appellant for AYs

ITA 2629/DEL/2023[2014-15]Status: DisposedITAT Delhi29 Aug 2024AY 2014-15

Bench: Shri M. Balaganesh & Shri Vimal Kumar

For Appellant: Shri Gaurav Jain, AdvFor Respondent: Shri P. N. Barnwal, CIT DR
Section 132Section 153ASection 153A(1)Section 153C

holding that for conducting assessments under sections 153A/153C of the Act, there must be ITA No. 2627, 2628 & 2629/Del/2023 Rajiv Agarwal incriminating evidence indicating undisclosed income, discovered during the search, thus, block of six assessment years under sections 153A/153C can only be possible prior to the date of search ... respect of concluded assessments, the AO would assume jurisdiction to reassess provided that the assets/documents received by the AO represent or indicate any undisclosed income or possibility of any income that may have remained undisclosed in the relevant assessment years. 22. The aforesaid principles would be equally applicable to proceedings

DCIT, CC-20, Delhi vs. Rajiv Agarwal, Delhi

In the result, the appeals of the appellant for AYs

ITA 2628/DEL/2023[2013-14]Status: DisposedITAT Delhi29 Aug 2024AY 2013-14

Bench: Shri M. Balaganesh & Shri Vimal Kumar

For Appellant: Shri Gaurav Jain, AdvFor Respondent: Shri P. N. Barnwal, CIT DR
Section 132Section 153ASection 153A(1)Section 153C

holding that for conducting assessments under sections 153A/153C of the Act, there must be ITA No. 2627, 2628 & 2629/Del/2023 Rajiv Agarwal incriminating evidence indicating undisclosed income, discovered during the search, thus, block of six assessment years under sections 153A/153C can only be possible prior to the date of search ... respect of concluded assessments, the AO would assume jurisdiction to reassess provided that the assets/documents received by the AO represent or indicate any undisclosed income or possibility of any income that may have remained undisclosed in the relevant assessment years. 22. The aforesaid principles would be equally applicable to proceedings

DCIT, CC-20, Delhi vs. Rajiv Agarwal, Delhi

In the result, the appeals of the appellant for AYs

ITA 2627/DEL/2023[2012-13]Status: DisposedITAT Delhi29 Aug 2024AY 2012-13

Bench: Shri M. Balaganesh & Shri Vimal Kumar

For Appellant: Shri Gaurav Jain, AdvFor Respondent: Shri P. N. Barnwal, CIT DR
Section 132Section 153ASection 153A(1)Section 153C

holding that for conducting assessments under sections 153A/153C of the Act, there must be ITA No. 2627, 2628 & 2629/Del/2023 Rajiv Agarwal incriminating evidence indicating undisclosed income, discovered during the search, thus, block of six assessment years under sections 153A/153C can only be possible prior to the date of search ... respect of concluded assessments, the AO would assume jurisdiction to reassess provided that the assets/documents received by the AO represent or indicate any undisclosed income or possibility of any income that may have remained undisclosed in the relevant assessment years. 22. The aforesaid principles would be equally applicable to proceedings

Manoj Mohandas Sukhwani, Ahmedabad vs. The Income Tax Officer, Ward-6(1)(3), Ahmedabad

The appeal of the assessee is allowed in above terms

ITA 273/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad28 Aug 2024AY 2017-18

Bench: Smt.Annapurna Guptaआयकर अपील सं / Ita No. 273/Ahd/2024 िनधा"रण वष"/Assessment Year: 2017-18 बनाम बनाम बनाम बनाम Manoj Mohandas Sukhwani, 103, 104, 1St Floor, Elegance The Income Tax Officer, Vs. Arcade, Nr. Bank Of India, Ward-6(1)(3), Station Road, Maninagar, Ahmedabad Ahmedabad-380008 Pan : Bayps 0941 P अपीलाथ"/ (Appellant) "त्यथ"/ (Respondent) िनधा" रती की ओर से / Assessee By : Shri S K Sadhwani, Ar "#थ% की ओर से / Revenue By: Shri Hrishikesh Hemant Patki, Sr Dr सुनवाई क" तारीख/Date Of Hearing : 30/07/2024 घोषणा क" तारीख /Date Of Pronouncement: 28/08/2024 आदेश आदेश/O R D E R आदेश आदेश

For Appellant: Shri S K Sadhwani, ARFor Respondent: Shri Hrishikesh Hemant Patki, Sr DR
Section 115BSection 133ASection 250Section 69A

grievously erred in making this addition of alleged surrendered income when the fact on record before them was that the assessee had already surrendered undisclosed income to the tune of Rs.53,27,500/- being the cash found deposited in his bank account during demonetization period and paid taxes thereon ... terms of the provisions of “Pradhan Mantri Garib Kalyan Yojana, 2016” [“PMGKY-2016” in short], which provided for the disclosure of undisclosed income deposited during demonetization in cash in banks. The ld. Counsel for the assessee contended that the assessee had been granted a certificate accepting the assessee’s disclosure

Saketkumar Rugnath Tanna, Ahmedabad vs. The DCIT, Central Circle-2(2), Ahmedabad

In the result the assessee appeal in ITA

ITA 978/AHD/2019[2014-15]Status: DisposedITAT Ahmedabad28 Aug 2024AY 2014-15

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 132Section 133ASection 139(1)Section 153A

held that where assessee retracted from disclosure made in statement under section 132(4) which was not accepted by Revenue, and if no undisclosed income was found during search, Revenue could not make addition on bare suspicion and presumption by observing as follows: “Section 69C, read with section ... assessee - Assessee retracted from disclosure made in statement under section 132(4) - Retraction was not accepted by Revenue - Assessing Officer made additions of undisclosed income - In fact, there was no reference to any undisclosed cash, jewellery, bullion, valuable article or documents containing any undisclosed income during search - Whether Assessing Officer

Saketkumar Rugnath Tanna, Ahmedabad vs. The DCIT, Central Circle-2(2), Ahmedabad

In the result the assessee appeal in ITA

ITA 977/AHD/2019[2007-08]Status: DisposedITAT Ahmedabad28 Aug 2024AY 2007-08

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 132Section 133ASection 139(1)Section 153A

held that where assessee retracted from disclosure made in statement under section 132(4) which was not accepted by Revenue, and if no undisclosed income was found during search, Revenue could not make addition on bare suspicion and presumption by observing as follows: “Section 69C, read with section ... assessee - Assessee retracted from disclosure made in statement under section 132(4) - Retraction was not accepted by Revenue - Assessing Officer made additions of undisclosed income - In fact, there was no reference to any undisclosed cash, jewellery, bullion, valuable article or documents containing any undisclosed income during search - Whether Assessing Officer

Saketkumar Rugnath Tanna Legal Heir of Late Smt. Indumatiben Rugnath Tanna, Ahmedabad vs. The DCIT, Central Circle-2(2), Ahmedabad

In the result the assessee appeal in ITA

ITA 976/AHD/2019[2014-15]Status: DisposedITAT Ahmedabad28 Aug 2024AY 2014-15

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 132Section 133ASection 139(1)Section 153A

held that where assessee retracted from disclosure made in statement under section 132(4) which was not accepted by Revenue, and if no undisclosed income was found during search, Revenue could not make addition on bare suspicion and presumption by observing as follows: “Section 69C, read with section ... assessee - Assessee retracted from disclosure made in statement under section 132(4) - Retraction was not accepted by Revenue - Assessing Officer made additions of undisclosed income - In fact, there was no reference to any undisclosed cash, jewellery, bullion, valuable article or documents containing any undisclosed income during search - Whether Assessing Officer

Smt. Ritaben Saketkumar Tanna, Ahmedabad vs. The DCIT, Central Circle-2(2), Ahmedabad

In the result the assessee appeal in ITA

ITA 975/AHD/2019[2014-15]Status: DisposedITAT Ahmedabad28 Aug 2024AY 2014-15

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 132Section 133ASection 139(1)Section 153A

held that where assessee retracted from disclosure made in statement under section 132(4) which was not accepted by Revenue, and if no undisclosed income was found during search, Revenue could not make addition on bare suspicion and presumption by observing as follows: “Section 69C, read with section ... assessee - Assessee retracted from disclosure made in statement under section 132(4) - Retraction was not accepted by Revenue - Assessing Officer made additions of undisclosed income - In fact, there was no reference to any undisclosed cash, jewellery, bullion, valuable article or documents containing any undisclosed income during search - Whether Assessing Officer

The ITO Ward-5(3)(1) (Previously the ACIT, Central Circle-2(2)), Ahmedabad vs. Shri Saketkumar Rugnath Tanna Legal Heir of Late Smt. Indumatiben Rugnath Tanna, Ahmedabad

In the result the assessee appeal in ITA

ITA 921/AHD/2019[2007-08]Status: DisposedITAT Ahmedabad28 Aug 2024AY 2007-08

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 132Section 133ASection 139(1)Section 153A

held that where assessee retracted from disclosure made in statement under section 132(4) which was not accepted by Revenue, and if no undisclosed income was found during search, Revenue could not make addition on bare suspicion and presumption by observing as follows: “Section 69C, read with section ... assessee - Assessee retracted from disclosure made in statement under section 132(4) - Retraction was not accepted by Revenue - Assessing Officer made additions of undisclosed income - In fact, there was no reference to any undisclosed cash, jewellery, bullion, valuable article or documents containing any undisclosed income during search - Whether Assessing Officer

The ACIT, Central Circle-2(2), Ahmedabad vs. Smt. Ritaben Saketkumar Tanna, Ahmedabad

In the result the assessee appeal in ITA

ITA 920/AHD/2019[2007-08]Status: DisposedITAT Ahmedabad28 Aug 2024AY 2007-08

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 132Section 133ASection 139(1)Section 153A

held that where assessee retracted from disclosure made in statement under section 132(4) which was not accepted by Revenue, and if no undisclosed income was found during search, Revenue could not make addition on bare suspicion and presumption by observing as follows: “Section 69C, read with section ... assessee - Assessee retracted from disclosure made in statement under section 132(4) - Retraction was not accepted by Revenue - Assessing Officer made additions of undisclosed income - In fact, there was no reference to any undisclosed cash, jewellery, bullion, valuable article or documents containing any undisclosed income during search - Whether Assessing Officer

Svm Cera Private Limited, Gujrat vs. ACIT, C.C-1(1). Kolkata., Kolkata

In the result, both the appeals in ITA Nos

ITA 974/KOL/2023[2015-16]Status: DisposedITAT Kolkata28 Aug 2024AY 2015-16

Bench: Shri Rajpal Yadav, Vp & Shri Dr. Manish Borad, Am

For Appellant: Shri P.K. Sanghai, ARFor Respondent: Shri Ankur Goyal, DR
Section 132Section 132(4)Section 143(3)Section 153ASection 271(1)(c)

post search scrutiny proceedings. However, the learned Assessing Officer initiated the penalty proceedings under Section 271(1)(c) of the Act for the undisclosed income declared during the course of search and finally vide order dated 29th June, 2017, levied the impugned penalty ITA Nos. 973 & 974/KOL/2023 SVM Cera Private ... learned Assessing Officer levied the impugned penalty under Section 271AAB(1)(a) of the Act at the rate of 10% of the undisclosed income / additional income surrendered by the assessee at ₹50 lacs. The learned CIT (A) is also confirmed the finding of the learned Assessing Officer. The learned counsel

Svm Cera Private Limited, Gujrat vs. ACIT, C.C-1(1), Kolkata

In the result, both the appeals in ITA Nos

ITA 973/KOL/2023[2014-15]Status: DisposedITAT Kolkata28 Aug 2024AY 2014-15

Bench: Shri Rajpal Yadav, Vp & Shri Dr. Manish Borad, Am

For Appellant: Shri P.K. Sanghai, ARFor Respondent: Shri Ankur Goyal, DR
Section 132Section 132(4)Section 143(3)Section 153ASection 271(1)(c)

post search scrutiny proceedings. However, the learned Assessing Officer initiated the penalty proceedings under Section 271(1)(c) of the Act for the undisclosed income declared during the course of search and finally vide order dated 29th June, 2017, levied the impugned penalty ITA Nos. 973 & 974/KOL/2023 SVM Cera Private ... learned Assessing Officer levied the impugned penalty under Section 271AAB(1)(a) of the Act at the rate of 10% of the undisclosed income / additional income surrendered by the assessee at ₹50 lacs. The learned CIT (A) is also confirmed the finding of the learned Assessing Officer. The learned counsel

A Govindaraj, Deputy Commissioner of Income Tax, Central Circle -2 Madurai, Central Range, Madurai vs. Chelladhurai Rajasingh, Sivakasi

In the result, the appeal filed by the Revenue stands dismissed

ITA 130/CHNY/2024[2013-2014]Status: DisposedITAT Chennai28 Aug 2024AY 2013-2014

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwalआयकर अपील सं./Ita No.130/Chny/2024 िनधा"रण वष"/Assessment Year: 2013-14 V. The Dcit, Shri Chelladhurai Rajasingh, Central Circle-2, No.84, Railway Feeder Road, Madurai. Kamarajar Road, Sivakasi-626 123. [Pan: Aaqpr 9845 L] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri I. Dinesh, AdvocateFor Respondent: Shri R. Clement Ramesh-
Section 132Section 132(4)Section 153C

Shri Chelladhurai Rajasingh :: 3 :: noted to have admitted the same by way of unexplained investment made out of his undisclosed income. Further, to avoid seizure of this excess jewellery, the assessee submitted equivalent value of demand draft of Rs.1.25 crs. which was deposited in the P.D. Account ... time of the search can’t be ignored, especially in view of its coherence. The AO noted that, the assessee had admitted to earning undisclosed income in other years by way of sale of scrap and therefore according to him, he would have earned undisclosed income from sale of scrap

DCIT, Central Circle-2, Trichy vs. Shri.N.Anbalagan, Pudukottai

In the result, the appeal filed by the Revenue is dismissed

ITA 344/CHNY/2022[2011-12]Status: DisposedITAT Chennai28 Aug 2024AY 2011-12

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.344/Chny/2022 िनधा"रण वष"/Assessment Year: 2011-12 The Deputy Commissioner Of Vs. Shri N. Anbalagan, Income Tax, Central Circle -2, 115, Pudukkottai Road, No. 44, Williams Road, Cantonment, Aranthangi, Pudukkottai 614 624. Trichy 620 001. [Pan: Aixpa4585F] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri V. Nandakumar, Cit ""थ" की ओर से/Respondent By : None सुनवाई की तारीख/ Date Of Hearing : 26.08.2024 घोषणा की तारीख /Date Of Pronouncement : 28.08.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Revenue Is Directed Against The Order Dated 28.02.2022 Passed By The Ld. Commissioner Of Income Tax (Appeals) 19, Chennai For The Assessment Year 2011-12. 2. We Find No Representation On Behalf Of The Assessee Nor Any Application Filed Seeking Adjournment. Thus, The Assessee Called Absent & Set Exparte. We Proceed To Decide The Appeal On Merits After Hearing The Ld. Dr Basing On The Material Available On Record.

For Appellant: Shri V. Nandakumar, CITFor Respondent: None
Section 144ASection 69A

dated 04.03.2019, which held the method of peak credit was rightly adopted for addition of the alleged undisclosed income of the assessee and is a well settled common principle. The relevant part at para 9 to 9.6 are reproduced herein below for ready reference: 9. I have pursued the assessment ... cash withdrawals in his bank account with the same bunk. Therefore, the method of Peak Credit was rightly adopted for addition of the alleged undisclosed income of the assessee and this is a well-settled and common principles so adopted. The finding of facts of the Authorities below cannot