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“Income-tax Officer”

Chapter I - PreliminarySection 2 - DefinitionsSection 2(25) / Section 1175,006 judgments

The decision most relied on for Income-tax Officer is CIT v. Max India Ltd. (295 ITR 282), cited in 1,162 judgments on BharatTax.

Leading authorities on Income-tax Officer

CIT v. Max India Ltd.
295 ITR 282 · 2007 · Supreme Court
1,162
citing judgments

Under Section 263, an assessment order is not erroneous and prejudicial to the interest of the revenue merely because the Principal Commissioner disagrees with the Assessing Officer's (AO) view, particularly if the AO has adopted one of two permissible views in law, unless that view is completely unsustainable. If due inquiries were made, the AO's order does not become erroneous solely because the fact of inquiries was not recorded.

Dhakeshwari Cotton Mills Ltd. v. CIT
26 ITR 775 · 1954 · Supreme Court
1,061
citing judgments

Corroborative evidence is essential to support evidence found on third-party premises, and an assessment cannot be based on suspicion, surmises, or conjecture.

Kale Khan Mohammad Hanif v. CIT
50 ITR 1 · 1963 · Supreme Court
581
citing judgments

The assessee bears the onus of proving the source and nature of any sum of money or receipt found to have been received by them. If the assessee fails to satisfactorily explain the receipt, the Income-tax Officer is entitled to treat it as taxable income.

Union of India v. Ashish Agarwal
444 ITR 1 · 2022 · Supreme Court
524
citing judgments

Notices issued under the unamended Section 148 of the Income-tax Act between April 1, 2021, and May 4, 2022, must be treated as notices issued under the new Section 148A(b) of the amended law. This requires the Assessing Officer to follow the procedure prescribed under the amended reassessment provisions, including issuing an order under Section 148A(d) before a fresh notice under Section 148.

CIT v. Kanpur Coal Syndicate
53 ITR 225 · 1964 · Supreme Court
359
citing judgments

The Commissioner (Appeals) holds plenary powers when disposing of an appeal, with their scope being coterminous with the Assessing Officer. This allows the CIT(A) to exercise all powers of the AO, including admitting additional evidence and redetermining income.

222 Taxman 15 (Gujarat)(MAG.), Principal Commissioner of Income-tax-4 v. G & G Pharma India Ltd.
384 ITR 147 · 2016 · High Court
274
citing judgments

An assessment can be reopened if there is tangible material indicating escapement of income, demonstrating a live link between the material and the reasons recorded for reopening. The Assessing Officer must apply their mind to the material facts, and the sanction under section 151 should not be based on borrowed satisfaction.

Paul Mathews & Sons. v. CIT
263 ITR 101 · 2003 · High Court
266
citing judgments

A statement recorded under Section 133A of the Income-tax Act has no evidentiary value because Section 133A does not empower an Income-tax Officer to examine any person on oath.

Navnitlal C. Javeri v. K.K. Sen
56 ITR 198 · 1965 · Supreme Court
230
citing judgments

The Supreme Court holds that circulars issued by the Central Board of Direct Taxes (CBDT) are binding on all officers and persons employed in the execution of the Income-tax Act. These circulars are binding even if they deviate from the provisions of the Act, particularly when issued to relieve hardships.

Judgments citing Income-tax Officer

Atul Manoharrao Yamsanwar, Nagpur vs. Assistant Commissioner of Income Tax, Central Circle 2(1), Nagpur

In the result, appeal of the Assessee is allowed

ITA 249/NAG/2022[2013-14]Status: DisposedITAT Nagpur09 Jun 2025AY 2013-14

Bench: Shri V. Durga Rao, Hon’Ble & Shri K.M. Roy, Hon’Ble Accountant, Member Atul Manoharrao Yamsanwar V. Acit – Central Circle – 2(1) Plot No. 33, Manoharrao Room No. 312, 3Rd Floor Khare Town, Dharampeth Aayakar Bhavan, Telangkhedi Road Nagpur - 440010 Civil Lines, Nagpur - 440001 Pan – Aaepy4543Q (Appellant) (Respondent)

Section 132Section 139Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 69ASection 69C

found. 4. It is held in the case (2020] 117 taxmann.com 986 (Gauhati - Trib.) IN THE ITAT GAUHATI BENCH 'E' Abdul Hamid Vs Income-tax Office that onus is Atul Manoharrao Yamsanwar on revenue department to prove the fact that assessee is the owner of the any money, bullion, jewellery ... acquisition of the money, bullion, jewellery or other valuable article, or the explanation offered by him is not, in the opinion of the Income-tax Officer, satisfactory, the money and the value of the bullion, jewellery or other valuable article may be deemed to be the income of the assessee

Vishwas Sudhakar Chaknalwar, Nagpur vs. Assistant Commissioner of Income Tax, Centra Circle 2(1), Nagpur

In the result, appeal filed by the Revenue is dismissed

ITA 238/NAG/2022[2020-21]Status: DisposedITAT Nagpur09 Jun 2025AY 2020-21

Bench: Shri V. Durga Rao, Hon’Ble & Shri K.M. Roy, Hon’Ble Accountant, Member Vishwas Sudhakar Chaknalwar V. Acit – Central Circle – 2(1) 801,8Th Floor & 800 Sq.Ft Space On 8Th Floor Room No. 312, 3Rd Floor Royal Park, Ramdaspeth Aayakar Bhavan Nagpur - 440012 Telangkhedi Road, Civil Lines Nagpur – 440002 Pan – Abdpc0828J (Appellant) (Respondent) Acit – Central Circle – 2(1) V. Vishwas Sudhakar Chaknalwar 801,8Th Floor & 800 Sq.Ft Space On 8Th Floor Room No. 312, 3Rd Floor Royal Park, Ramdaspeth Aayakar Bhavan Nagpur – 440012 Telangkhedi Road, Civil Lines Nagpur – 440001 Pan – Abdpc0828J (Appellant) (Respondent)

Section 132Section 133ASection 139(4)Section 142(1)Section 143(2)Section 143(3)Section 153ASection 69A

explained the entries stating that the letter "W" put against payment is "White" while the letter "B" were put against payment is "Black". Income-tax officer made additions on the basis of entries as in the seized material alleging that these payments were outside the books of accounts and also ... relied upon the statements made by these two persons. The Appellate Assistant Commissioner confirmed the additions made by the Income-tax Officer. 9.5.1. Before the Tribunal, it was contended on behalf of the assessee that the entire evidence merely created suspicion and it did not take the place of proof

Aamir Khan Production Private Limited, Mumbai vs. Pr CIT-8, Mumbai

In the result, the appeal filed by the assessee is

ITA 2612/MUM/2025[2020-21]Status: DisposedITAT Mumbai09 Jun 2025AY 2020-21

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Respondent byFor Respondent: Date of Hearing
Section 135Section 143(2)Section 143(3)Section 263Section 37Section 37(1)Section 80G

aforesaid definitions it is clear that an order cannot be termed as erroneous unless it is not in accordance with law. If an Income-tax Officer acting in accordance with law makes a certain assessment, the same cannot be branded as erroneous by the Commissioner simply because, according ... been written more elaborately. This section does not visualize a case of substitution of the judgment of the Commissioner for that of the Income-tax Officer, who passed the order unless the decisions is held to be erroneous. Cases may be visualized where the Income-tax Officer while making

Laxmanbhai Nathubhai Zora, Porbandar vs. ITO Ward 2(3), Rajkot, Porbandar

ITA 745/RJT/2024[2012-2013]Status: DisposedITAT Rajkot06 Jun 2025AY 2012-2013

Bench: Dr. Arjun Lal Saini(Hybrid Hearing) Assessment Year: (2012-13) Laxmanbhainathubhai Zora Vs. Ito, Ward-2(3) Rameshwari Krupa, Nr.Railway Pata Rajkot, Porbandar. Thakkar Plot, Porbandar. Pan : Aakpz 1087 E (Appellant) (Respondent)

For Appellant: Shri Gaurang Khakhkhar, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr.DR
Section 133(6)Section 139Section 143(3)Section 147Section 148Section 250

Income Tax, Jamnagar was obtained for re-opening proceedings. Accordingly, notice u/s 148 of the Income tax Act, 1961 was issued by the Income-tax Officer, Ward 2(3), Porbandar, on 27.03.2019 and served upon assessee on 28.03.2019. But the assessee has not submitted her return of income within

Sachidanandaiah Ganesh, Tamil Nadu vs. Income-Tax Officer Ward 1, Hosur

In the result, the appeal filed by the assessee is allowed

ITA 190/CHNY/2025[2017-18]Status: DisposedITAT Chennai06 Jun 2025AY 2017-18

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:190/Chny/2025 िनधा"रण वष" / Assessment Year: 2017-18 Sachidanandaiah Ganesh, Income Tax Officer, 37, Vaniyar Street, Vs. Ward 1, Kelamangalam, Hosur. Krishnagiri, Tamil Nadu- 635 113. [Pan: Ajipg-9330-N] (अपीलाथ"/Appellant) (""थ"/Respondent)

For Appellant: Shri. Sandeep Chalapathy, C.AFor Respondent: Ms. Anitha Addl.C.I.T
Section 143(3)Section 69A

taxmann.com 377 (Delhi- Trib.) (c) Uma Agarwal vs. ITO [2021] 127 taxmann.com 735 (Agra-Trib.) (d) Abdul Razaak vs. Income-tax Officer, (International Taxation) [2023] 153 taxmann.com 180 (Chennai-Trib.) :-4-: ITA. No.:190 /Chny/2025 6. On perusal of the submissions made by the assessee, the ld.CIT(A), NFAC

DCIT, Circle - 19(1), Delhi vs. Pc Jeweller Limited, Delhi

ITA 3084/DEL/2024[2016-17]Status: DisposedITAT Delhi06 Jun 2025AY 2016-17

Bench: Ms. Madhumita Roy & Shri Khettra Mohan Roy

Section 115JSection 143(1)Section 35D

1 ITA Nos.2581 & 3084/Del/2024 C.O. Nos.67 & 96/Del/2024 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “F”: NEW DELHI BEFORE Ms

Deputy Commissioner of Income Tax, Cr Building vs. Pc Jeweller Limited, Delhi

ITA 2581/DEL/2024[2015-16]Status: DisposedITAT Delhi06 Jun 2025AY 2015-16

Bench: Ms. Madhumita Roy & Shri Khettra Mohan Roy

Section 115JSection 143(1)Section 35D

1 ITA Nos.2581 & 3084/Del/2024 C.O. Nos.67 & 96/Del/2024 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “F”: NEW DELHI BEFORE Ms

Mahendra Singh Naruka, Jaipur vs. Assistant Commissioner of Income Tax, Central Circle-3, Jaipur

In the result, the appeal of the assesseein ITA no

ITA 205/JPR/2025[2016-17]Status: DisposedITAT Jaipur04 Jun 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकरअपीलसं. / ITA. No. 204 & 205/JPR/2025 निर्धारणवर्ष / AssessmentYears : 2015-16 & 2016-17 Shri Mahendra Singh Naruka B-536, J.D.A. Colony Malivya Nagar, Jaipur 302 017 अपीलार्थी / Appellant स्थायीलेखा सं. / जीआईआरसं./PAN/GIR No.: ABUPN 1656 J बनाम Vs. The ACIT Central Circle-3 Jaipur प्रत्यर्थी / Respondent निधर्धारिती की ओरसे / Assesseeby : Shri S.R. Sharma, Advocate राजस्व की ओरसे /Revenue by : Mrs. Anita Rinesh

For Appellant: Shri S.R. Sharma, AdvocateFor Respondent: Mrs. Anita Rinesh, JCIT -DR a
Section 115BSection 143(3)Section 153ASection 68

that where an assessee fails to prove satisfactorily the source and nature of certain amount of cash received during the accounting year, the Income-tax Officer is entitled to draw the inference that the receipts are of an assessable nature. In the case of Kale Khan Mohammad Hanif v. Commissioner ... that if it was, it was exempt from taxation under the provisions of the Act in the absence of such proof the Income-tax Officer is entitled to treat it as taxable income see A Govindarajulu Mudaliar v. Commissioner of Income-tax [1956] 34 ITR 807 (SC)’’ Referring

Mahendra Singh Naruka, Jaipur vs. Assistant Commissioner of Income Tax, Central Circle-3, Jaipur

In the result, the appeal of the assesseein ITA no

ITA 204/JPR/2025[2015-16]Status: DisposedITAT Jaipur04 Jun 2025AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकरअपीलसं. / ITA. No. 204 & 205/JPR/2025 निर्धारणवर्ष / AssessmentYears : 2015-16 & 2016-17 Shri Mahendra Singh Naruka B-536, J.D.A. Colony Malivya Nagar, Jaipur 302 017 अपीलार्थी / Appellant बनाम Vs. The ACIT Central Circle-3 Jaipur प्रत्यर्थी / Respondent स्थायीलेखा सं. / जीआईआरसं./PAN/GIR No.: ABUPN 1656 J निधर्धारिती की ओरसे / Assesseeby : Shri S.R. Sharma, Advocate राजस्व की ओरसे /Revenue by : Mrs. Anita Rinesh

For Appellant: Shri S.R. Sharma, AdvocateFor Respondent: Mrs. Anita Rinesh, JCIT -DR a
Section 115BSection 143(3)Section 153ASection 68

that where an assessee fails to prove satisfactorily the source and nature of certain amount of cash received during the accounting year, the Income-tax Officer is entitled to draw the inference that the receipts are of an assessable nature. In the case of Kale Khan Mohammad Hanif v. Commissioner ... that if it was, it was exempt from taxation under the provisions of the Act in the absence of such proof the Income-tax Officer is entitled to treat it as taxable income see A Govindarajulu Mudaliar v. Commissioner of Income-tax [1956] 34 ITR 807 (SC)’’ Referring

Rekha Shah, Mumbai vs. AO, Kautilya Bhavan, Mumbai

In the result, the appeal filed by the assessee bearing ITA No

ITA 2311/MUM/2025[2011-12]Status: DisposedITAT Mumbai04 Jun 2025AY 2011-12

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjeerekha Shah Vs National Faceless Appeal Centre D-614, Veena Santoor, Sector- (Nfac) / Ito-Ward-34(3)(2), 8, Opp. Kvsc, Sai Baba Nagar Mumbai Extension Road, Borivali (W), Kautilya Bhavan, Bkc, Banda, Mumbai-400 092 Mumbai-400 051 Pan: Abgps4732G Appellant Respondent

For Appellant: Shri Vimal PunmiyaFor Respondent: Shri Annavaram Kosuri (SR DR)
Section 144Section 147Section 250

short, ‘the Act’) for A.Y. 2011-12, date of order 25/07/2023. The impugned order was emanated from the order of the Learned Income-tax Officer, Ward 25(3)(3), Mumbai(in short, the “Ld. AO”) 2 Rekha Shah passed under section 144 read with section 147 of the Act, date

Arvind Kumar Prop. M/S Shree Balaji Trading Co., Panipat vs. Addl/Jt/Asst Commissioner of Income Tax/Income Tax Officer, NFAC, Delhi

ITA 5400/DEL/2024[2017-2018]Status: DisposedITAT Delhi04 Jun 2025AY 2017-2018

Bench: Shri S.Rifaur Rahman

For Appellant: Shri Somil Aggarwal, AdvocateFor Respondent: Shri Sanjay Kumar, Sr. DR
Section 115BSection 143(2)Section 148Section 68

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘SMC': NEW DELHI BEFORE SHRI S.RIFAUR RAHMAN, ACCOUNTANT MEMBER ITA No.5400/DEL/2024 (Assessment

Sushil Kumar, Delhi vs. ACIT - Circle -22(2), Delhi

In the result, Appeal of the Assessee is allowed

ITA 3481/DEL/2024[2013-14]Status: DisposedITAT Delhi04 Jun 2025AY 2013-14

Bench: Shri M. Balaganesh & Sh. Yogesh Kumar U.S.Sushil Kumar Vs. Acit Shreeram Overseas Circle-22(2) 5520, Basti Harpull C. R. Building, Singh, Sadar Bazar, Delhi Delhi Pan: Aalpk5068M Appellant Respondent

Section 132Section 143(2)Section 143(3)Section 144BSection 147Section 148Section 151ASection 153ASection 69A

find that similar argument of the Revenue was negated by the Hon'ble Delhi High Court in Ram Balram Buildhome (P.) Ltd. v/s Income-tax Officer, reported in [2025] 171 taxmann.com 99 (Delhi), by observing as follows: - "69. As noted above, by virtue of TOLA, the AO had period

Darshit Patel, Sanganer, Jaipur vs. Income Tax Officer Ward 7(2), Jaipur

In the result appeal filed by the assessee stands allowed and that of

ITA 957/JPR/2024[2013-2014]Status: DisposedITAT Jaipur03 Jun 2025AY 2013-2014

Bench: Him.

For Appellant: Sh. Mukesh Goyal, CAFor Respondent: Sh. Anup Singh, Addl. CIT-DR
Section 147Section 44ASection 69A

Teena Bethala Vs Income Tax Officer, Ward – 4(3)(2), Bengaluru. ITA Nos.1383 and 1384/Bang/2019, dated 28.08.2019 2. Smt. Gangambike, Vs The Income-tax Officer, Ward – 3[2][3], Bangalore. ITA No.2598/Bang/2018,, 07.12.2018 3. Dy Commissioner of Income Tax Act Vs Kartihik Contruction Co. Mumbai… ITA no.2292/Mum./2016

Income Tax Officer, Ward-7(2), Jaipur vs. Darshit Patel, Jaipur

In the result appeal filed by the assessee stands allowed and that of

ITA 929/JPR/2024[2013-14]Status: DisposedITAT Jaipur03 Jun 2025AY 2013-14

Bench: Him. 2. Since These Cross Appeals Relate One Assessee Involving The Same

For Appellant: Sh. Mukesh Goyal, CAFor Respondent: Sh. Anup Singh, Addl. CIT-DR
Section 147Section 44ASection 69A

Teena Bethala Vs Income Tax Officer, Ward – 4(3)(2), Bengaluru. ITA Nos.1383 and 1384/Bang/2019, dated 28.08.2019 2. Smt. Gangambike, Vs The Income-tax Officer, Ward – 3[2][3], Bangalore. ITA No.2598/Bang/2018,, 07.12.2018 3. Dy Commissioner of Income Tax Act Vs Kartihik Contruction Co. Mumbai... ITA no.2292/Mum./2016

Ramesh Kumar, Jhunjhunu vs. ITO Ward-1, Jhunjhunu

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

ITA 1182/JPR/2024[2013-14]Status: DisposedITAT Jaipur03 Jun 2025AY 2013-14
For Appellant: Shri Sharwan Kumar Gupta, AdvocateFor Respondent: Shri Gautam Singh Choudhary, JCIT-DR
Section 115BSection 147Section 148Section 151Section 234ASection 250Section 69

held as that:- " It has to be noted, however, that beyond these calculations of figures, no further scrutiny was made by the Income-tax Officer or the Appellate Assistant Commissioner of the entries in the cash book of the appellants. The cash book of the appellants was accepted ... either party. The appellants took it that the affidavits of these parties were enough and neither the Appellate Assistant Commissioner, nor the Income-tax Officer, who was present at the hearing of the appeal before the Appellate Assistant Commissioner, considered it necessary to call for them in order to cross

Ramesh Kumar, Jhunjhunu vs. ITO Ward-1 Jhunjhunu, Jhunjhunu

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

ITA 1180/JPR/2024[2013-14]Status: DisposedITAT Jaipur03 Jun 2025AY 2013-14
For Appellant: Shri Sharwan Kumar Gupta, AdvocateFor Respondent: Shri Gautam Singh Choudhary, JCIT-DR
Section 115BSection 144Section 147Section 148Section 151Section 234ASection 250Section 69

held as that:- " It has to be noted, however, that beyond these calculations of figures, no further scrutiny was made by the Income-tax Officer or the Appellate Assistant Commissioner of the entries in the cash book of the appellants. The cash book of the appellants was accepted ... either party. The appellants took it that the affidavits of these parties were enough and neither the Appellate Assistant Commissioner, nor the Income-tax Officer, who was present at the hearing of the appeal before the Appellate Assistant Commissioner, considered it necessary to call for them in order to cross

Ramesh Kumar, Jhunjhunu vs. ITO Ward-1, Jhunjhunu

ITA 1179/JPR/2024[2013-14]Status: DisposedITAT Jaipur03 Jun 2025AY 2013-14

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Sharwan Kumar Gupta, AdvocateFor Respondent: Shri Gautam Singh Choudhary, JCIT-DR
Section 115BSection 144Section 147Section 148Section 151Section 234ASection 250Section 69

held as that:- " It has to be noted, however, that beyond these calculations of figures, no further scrutiny was made by the Income-tax Officer or the Appellate Assistant Commissioner of the entries in the cash book of the appellants. The cash book of the appellants was accepted ... either party. The appellants took it that the affidavits of these parties were enough and neither the Appellate Assistant Commissioner, nor the Income-tax Officer, who was present at the hearing of the appeal before the Appellate Assistant Commissioner, considered it necessary to call for them in order to cross

Goldman Sachs (India) Securities Pvt.Ltd, Mumbai vs. ACIT Cir 7 (1) (1), Mumbai

In the result, ground no. 8 and 9 are allowed for statistical purpose

ITA 2436/MUM/2022[2018-19]Status: DisposedITAT Mumbai03 Jun 2025AY 2018-19

Bench: Shri Pawan Singh&Girish Agrawal(Physical Hearing) Goldman Sachs (India) Securities Acit, Circle-7(1)(1), Private Limited, 951-A, Rational House, Vs Aayakarbhawan, Mumbai- Appasaheb Marathe Marg, Prabhadevi, 400020. Mumbai-400025. [Pan No. Aafca6819F] Appellant / Assessee Respondent / Revenue

Section 143(3)Section 144BSection 254(1)Section 92C

assessment proceedings for AY 2016-17 or any other year. In disregarding the order of Hon'ble Mumbai ITAT in the case of Income-tax officer vs Reliance Share and Stock Brokers Private Limited (51 taxmann.com 215) and DCIT v. Anil DhirajlalAmbani (ITA No. 3676/Mum/2016) and order

Ila Jitendra Mehta, Mumbai vs. DCIT Central Circle 8(4), Mumbai

In the result, the appeal of the Assessee is allowed

ITA 5219/MUM/2024[2014-15]Status: DisposedITAT Mumbai02 Jun 2025AY 2014-15

Bench: Shri Narender Kumar Choudhry & Smt Renu Jauhriassessment Year: 2014-15

For Appellant: Shri Ravi Ganatra, Ld. A.RFor Respondent: Shri Yogesh Kumar, Ld. Sr. DR
Section 133Section 139(1)Section 250Section 271(1)(c)Section 54F

said that the said Explanation applies because of the discrepancy between the income returned by the petitioner and the income assessed by the Income-tax Officer. In the case of Burmah- Shell Oil Storage & Distributing Co. of India Ltd. (supra), the Hon'ble Calcutta High Court had taken this view

Rishabh Steel Supplier, Gandhidham vs. DCIT, CC-1, Rajkot

In the result, all these appeals filed by the different assessees, are allowed for statistical purposes

ITA 414/RJT/2023[2021-22]Status: DisposedITAT Rajkot30 May 2025AY 2021-22

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha(Hybrids Hearing) आयकरअपीलसं./Ita No.400/Rjt/2023 Assessment Year: (2021-22)

Section 143(3)Section 250

holding that estimation of sales on the basis of loose slips represented payment of wages is not possible."  In case of Additional Income-Tax Officer Vs T. Mudduveerappa Sons. [1992 (12) TMI 62-ITAT Bangalore), the Bangalore Bench of ITAT held that in absence of any external evidence, addition cannot