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514 results for “section 68”+ Section 66clear

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Key Topics

Addition to Income82Section 143(3)61Section 13258Section 6853Section 153A52Search & Seizure48Section 153C45Section 37(1)42Section 153B30

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE3-(1), HYDERABAD vs. VAISHNAVI BULLION PRIVATE LIMITED, HYDERABAD

In the result, we uphold the addition of Rs

ITA 58/HYD/2021[2017-18]Status: DisposedITAT Hyderabad28 Nov 2022AY 2017-18

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

For Appellant: Shri S.K. Gupta, AdvocateFor Respondent: Shri Vijay Bhaskar Reddy
Section 131Section 68

section 164 of Cr.PC. viii. The assessee had not filled any receipts issued by it in favour of seven persons as alleged by him in subsequent statement dated 20/11/2019. ix. It is not the case of the assessee that at the time of recording of statement during survey, seven person including Neel sunder were present and had pressurized

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE3-(1), HYDERABAD vs. M/S. MUSADDILAL GEMS AND JEWELS PRIVATE LIMITED, HYDERABAD

In the result, we uphold the addition of Rs

Showing 1–20 of 514 · Page 1 of 26

...
Section 80I29
Disallowance23
Deduction20
ITA 59/HYD/2021[2017-18]Status: DisposedITAT Hyderabad28 Nov 2022AY 2017-18

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

For Appellant: Shri S.K. Gupta, AdvocateFor Respondent: Shri Vijay Bhaskar Reddy
Section 131Section 68

section 164 of Cr.PC. viii. The assessee had not filled any receipts issued by it in favour of seven persons as alleged by him in subsequent statement dated 20/11/2019. ix. It is not the case of the assessee that at the time of recording of statement during survey, seven person including Neel sunder were present and had pressurized

VAISHNAVI BULLION PRIVATE LIMITED ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(1), HYDERABAD

In the result, we uphold the addition of Rs

ITA 561/HYD/2020[2017-18]Status: DisposedITAT Hyderabad28 Nov 2022AY 2017-18

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

For Appellant: Shri S.K. Gupta, AdvocateFor Respondent: Shri Vijay Bhaskar Reddy
Section 131Section 68

section 164 of Cr.PC. viii. The assessee had not filled any receipts issued by it in favour of seven persons as alleged by him in subsequent statement dated 20/11/2019. ix. It is not the case of the assessee that at the time of recording of statement during survey, seven person including Neel sunder were present and had pressurized

MUSADDILAL GEMS JEWELS PRIVATE LIMITED ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(1), HYDERABAD

In the result, we uphold the addition of Rs

ITA 560/HYD/2020[2017-18]Status: DisposedITAT Hyderabad28 Nov 2022AY 2017-18

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

For Appellant: Shri S.K. Gupta, AdvocateFor Respondent: Shri Vijay Bhaskar Reddy
Section 131Section 68

section 164 of Cr.PC. viii. The assessee had not filled any receipts issued by it in favour of seven persons as alleged by him in subsequent statement dated 20/11/2019. ix. It is not the case of the assessee that at the time of recording of statement during survey, seven person including Neel sunder were present and had pressurized

DEEPALI KAPOOR,HYDERABAD vs. ITO., WARD-12(1), HYDERABAD

In the result, the appeal of the is allowed for statistical purposes

ITA 1097/HYD/2025[2022-2023]Status: DisposedITAT Hyderabad19 Nov 2025AY 2022-2023

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1097/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2022-23) Ms. Deepali Kapoor Vs. Income Tax Officer Hyderabad Ward 12 (1) Pan:Annpk2904M Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Ca Pawan Kumar Chakrapani राज" व "ारा/Revenue By:: Shri R. Kumaran, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 12/11/2025 घोषणा की तारीख/Pronouncement: 19/11/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Ms. Deepali Kapoor (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) Dated 10.06.2025 For The A.Y 2022-23. 2. The Assessee Has Raised The Following Grounds Of Appeal: “1. The Impugned Order Of The Learned Authorities Below In So Far As It Is Against The Appellant Is Opposed To Law, Weight Of Page 1 Of 7

For Appellant: CA Pawan Kumar ChakrapaniFor Respondent: : Shri R. Kumaran, Sr. DR
Section 143(2)Section 143(3)Section 144BSection 234BSection 68

section 68 of the Act is wholly unsustainable and liable to be deleted. 6. As regards to addition of Rs.17,80,000/- (capital account credit difference) the Ld. AR invited our attention to the assessee’s bank statement with HDFC Bank placed at page no. 66

DCIT, CIRCLE-1(2), HYDERABAD, HYDERABAD vs. BRAMHANI INDUSTRIES LIMITED, JAMMALAMADUGU, YSR DIST., YSR DIST.

In the result, appeal of the assessee is partly allowed and the appeal of the Revenue is dismissed

ITA 398/HYD/2017[2010-11]Status: DisposedITAT Hyderabad06 Jan 2022AY 2010-11

Bench: Shri A. Mohan Alankamony & Sri Chandra Mohan Garga.Y. 2010-11 Bramhani Industries Limited, Vs. Dcit, Jammalamadugu. Circle-1(3), Pan: Aadcb 1666 M Hyderabad. (Appellant) (Respondent) Ay: 2010-11 Dcit, Vs. Bramhani Industries Circle-1(2), Limited, Hyderabad. Jammalamadugu. Pan: Aadcb 1666 M (Appellant) (Respondent) Assessee By Sri Gowtham Jain Revenue By Sri K.V. Aravind, Sr. Standing Counsel For Dr Date Of Hearing: 12/10/2021 Date Of Pronouncement: 06/01/2022 Order

Section 144Section 234ASection 249(3)Section 68

section 68 of the Act. On appeal, the Ld. CIT (A) after hearing the Ld. AR on few occasions upheld the order of the Ld. AO as he was also of the view that the identity, creditworthiness, genuineness of the transaction have not been established. While arriving at such decision, he relied on the second remand report obtained from

BRAMHANI INDUSTRIES LIMITED, JAMMALAMADUGU,KADAPA vs. DCIT, CIRCLE-1(3), HYDERABAD, HYDERABAD

In the result, appeal of the assessee is partly allowed and the appeal of the Revenue is dismissed

ITA 512/HYD/2017[2010-11]Status: DisposedITAT Hyderabad06 Jan 2022AY 2010-11

Bench: Shri A. Mohan Alankamony & Sri Chandra Mohan Garga.Y. 2010-11 Bramhani Industries Limited, Vs. Dcit, Jammalamadugu. Circle-1(3), Pan: Aadcb 1666 M Hyderabad. (Appellant) (Respondent) Ay: 2010-11 Dcit, Vs. Bramhani Industries Circle-1(2), Limited, Hyderabad. Jammalamadugu. Pan: Aadcb 1666 M (Appellant) (Respondent) Assessee By Sri Gowtham Jain Revenue By Sri K.V. Aravind, Sr. Standing Counsel For Dr Date Of Hearing: 12/10/2021 Date Of Pronouncement: 06/01/2022 Order

Section 144Section 234ASection 249(3)Section 68

section 68 of the Act. On appeal, the Ld. CIT (A) after hearing the Ld. AR on few occasions upheld the order of the Ld. AO as he was also of the view that the identity, creditworthiness, genuineness of the transaction have not been established. While arriving at such decision, he relied on the second remand report obtained from

SABITHA ANAND HOSPITAL,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3(3), HYDERABAD

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

ITA 597/HYD/2022[2017-18]Status: DisposedITAT Hyderabad17 Mar 2023AY 2017-18

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2017-18 M/S.Sabitha Anand Vs. Dy. C. I. T. Hospital, Hyderabad Central Circle 3(3) Pan:Abwfs9326E Hyderabad (Appellant) (Respondent) Assessee By: Shri A.V. Raghuram, Advocate Revenue By: Shri Kumar Aditya, Dr Date Of Hearing: 02/03/2023 Date Of Pronouncement: 17/03/2023 Order Per R.K. Panda, A.M This Appeal Filed By The Assessee Is Directed Against The Order Dated 7.9.2022 Of The Learned Cit (A)-11, Hyderabad, Relating To A.Y.2017-18. 2. Facts Of The Case, In Brief, Are That The Assessee Is A Partnership Firm Engaged In The Business Of Running A Hospital In The Name Of M/S. Sabitha Anand Hospitals. It Filed Its Original Return Of Income On 28.10.2017 Declaring Total Income Of Rs.10,70,540/-. A Survey U/S 133A Of The Act Was Conducted In The Case Of The Assessee On 27.9.2016. Consequent To The Survey Operation, The Assessee Filed A Revised Computation Of Income Of Page 1 Of 17

For Appellant: Shri A.V. Raghuram, AdvocateFor Respondent: Shri Kumar Aditya, DR
Section 115BSection 133ASection 143(2)Section 69

68, section 69, section 69A, section 69B, section 69C or section 69D, if such income is not covered under clause (a), the income-tax payable shall be the aggregate of (i the amount of income-tax calculated on the income referred to in clause (a) and clause (b), at the rate of sixty per cent

ANIRUDH VENKATA RAGI ,HYDERABAD vs. INCOME TAX OFFICER, WARD-4(2), HYDERABAD

In the result, appeal of the assessee is dismissed

ITA 352/HYD/2019[2015-16]Status: DisposedITAT Hyderabad21 Nov 2023AY 2015-16

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Chary

For Appellant: Shri S. Rama Rao, ARFor Respondent: Ms. Sheetal Sarin, DR
Section 10(38)Section 143(3)

66,46,410/-, received through a media approved by the Central Government, and, therefore, the provisions of Section 10(38) of the Act come into play. 10. He further argued that there is no evidence with the learned Assessing Officer to reach a conclusion that the transaction is a bogus one inasmuch as the shares were allotted

PUJALA MAHESH BABU ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, all the four appeals filed by the assessee are partly allowed and the only appeal filed by the Revenue is dismissed

ITA 134/HYD/2019[2014-15]Status: DisposedITAT Hyderabad26 Sept 2022AY 2014-15

Bench: Shri R.K. Panda & Shri K. Narasimha Charyappeal In Ita No Assessee Revenue A.Y 132/Hyd/2018 Shri Pujala Mahesh A.C.I.T. Central 2012-13 Babu, Hyderabad Circle-2(3) Hyderabad Pan:Aeppp5729L 133/Hyd/2019 -Do- -Do- 2013-14 134/Hyd/2019 -Do- -Do- 2014-15 135/Hyd/2019 -Do- -Do- 2015-16 126/Hyd/2019 A.C.I.T. Central Shri Pujala Mahesh 2013-14 Circle-2(3) Babu, Hyderabad Hyderabad Pan:Aeppp5729L Assessee By: Shri S. Rama Rao, Advocate Revenue By: Shri Solgy Jose T. Kottaram,Dr

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: Shri Solgy Jose T. Kottaram,DR
Section 132Section 133ASection 143(3)Section 153ASection 234A(3)

68 nor the provisions of section 69 are applicable. He submitted that the said amount was never received as the income of the assessee and the seized material also does not provide any such information. Therefore, the amount cannot be added and hence should be deleted. 40. The learned DR, on the other hand, heavy relied on the order

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), HYDERABAD vs. PUJALA MAHESH BABU , RANGA REDDY

In the result, all the four appeals filed by the assessee are partly allowed and the only appeal filed by the Revenue is dismissed

ITA 126/HYD/2019[2013-14]Status: DisposedITAT Hyderabad26 Sept 2022AY 2013-14

Bench: Shri R.K. Panda & Shri K. Narasimha Charyappeal In Ita No Assessee Revenue A.Y 132/Hyd/2018 Shri Pujala Mahesh A.C.I.T. Central 2012-13 Babu, Hyderabad Circle-2(3) Hyderabad Pan:Aeppp5729L 133/Hyd/2019 -Do- -Do- 2013-14 134/Hyd/2019 -Do- -Do- 2014-15 135/Hyd/2019 -Do- -Do- 2015-16 126/Hyd/2019 A.C.I.T. Central Shri Pujala Mahesh 2013-14 Circle-2(3) Babu, Hyderabad Hyderabad Pan:Aeppp5729L Assessee By: Shri S. Rama Rao, Advocate Revenue By: Shri Solgy Jose T. Kottaram,Dr

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: Shri Solgy Jose T. Kottaram,DR
Section 132Section 133ASection 143(3)Section 153ASection 234A(3)

68 nor the provisions of section 69 are applicable. He submitted that the said amount was never received as the income of the assessee and the seized material also does not provide any such information. Therefore, the amount cannot be added and hence should be deleted. 40. The learned DR, on the other hand, heavy relied on the order

PUJALA MAHESH BABU ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, all the four appeals filed by the assessee are partly allowed and the only appeal filed by the Revenue is dismissed

ITA 135/HYD/2019[2015-16]Status: DisposedITAT Hyderabad26 Sept 2022AY 2015-16

Bench: Shri R.K. Panda & Shri K. Narasimha Charyappeal In Ita No Assessee Revenue A.Y 132/Hyd/2018 Shri Pujala Mahesh A.C.I.T. Central 2012-13 Babu, Hyderabad Circle-2(3) Hyderabad Pan:Aeppp5729L 133/Hyd/2019 -Do- -Do- 2013-14 134/Hyd/2019 -Do- -Do- 2014-15 135/Hyd/2019 -Do- -Do- 2015-16 126/Hyd/2019 A.C.I.T. Central Shri Pujala Mahesh 2013-14 Circle-2(3) Babu, Hyderabad Hyderabad Pan:Aeppp5729L Assessee By: Shri S. Rama Rao, Advocate Revenue By: Shri Solgy Jose T. Kottaram,Dr

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: Shri Solgy Jose T. Kottaram,DR
Section 132Section 133ASection 143(3)Section 153ASection 234A(3)

68 nor the provisions of section 69 are applicable. He submitted that the said amount was never received as the income of the assessee and the seized material also does not provide any such information. Therefore, the amount cannot be added and hence should be deleted. 40. The learned DR, on the other hand, heavy relied on the order

PUJALA MAHESH BABU,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, all the four appeals filed by the assessee are partly allowed and the only appeal filed by the Revenue is dismissed

ITA 132/HYD/2019[2012-13]Status: DisposedITAT Hyderabad26 Sept 2022AY 2012-13

Bench: Shri R.K. Panda & Shri K. Narasimha Charyappeal In Ita No Assessee Revenue A.Y 132/Hyd/2018 Shri Pujala Mahesh A.C.I.T. Central 2012-13 Babu, Hyderabad Circle-2(3) Hyderabad Pan:Aeppp5729L 133/Hyd/2019 -Do- -Do- 2013-14 134/Hyd/2019 -Do- -Do- 2014-15 135/Hyd/2019 -Do- -Do- 2015-16 126/Hyd/2019 A.C.I.T. Central Shri Pujala Mahesh 2013-14 Circle-2(3) Babu, Hyderabad Hyderabad Pan:Aeppp5729L Assessee By: Shri S. Rama Rao, Advocate Revenue By: Shri Solgy Jose T. Kottaram,Dr

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: Shri Solgy Jose T. Kottaram,DR
Section 132Section 133ASection 143(3)Section 153ASection 234A(3)

68 nor the provisions of section 69 are applicable. He submitted that the said amount was never received as the income of the assessee and the seized material also does not provide any such information. Therefore, the amount cannot be added and hence should be deleted. 40. The learned DR, on the other hand, heavy relied on the order

PUJALA MAHESH BABU,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, all the four appeals filed by the assessee are partly allowed and the only appeal filed by the Revenue is dismissed

ITA 133/HYD/2019[2013-14]Status: DisposedITAT Hyderabad26 Sept 2022AY 2013-14

Bench: Shri R.K. Panda & Shri K. Narasimha Charyappeal In Ita No Assessee Revenue A.Y 132/Hyd/2018 Shri Pujala Mahesh A.C.I.T. Central 2012-13 Babu, Hyderabad Circle-2(3) Hyderabad Pan:Aeppp5729L 133/Hyd/2019 -Do- -Do- 2013-14 134/Hyd/2019 -Do- -Do- 2014-15 135/Hyd/2019 -Do- -Do- 2015-16 126/Hyd/2019 A.C.I.T. Central Shri Pujala Mahesh 2013-14 Circle-2(3) Babu, Hyderabad Hyderabad Pan:Aeppp5729L Assessee By: Shri S. Rama Rao, Advocate Revenue By: Shri Solgy Jose T. Kottaram,Dr

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: Shri Solgy Jose T. Kottaram,DR
Section 132Section 133ASection 143(3)Section 153ASection 234A(3)

68 nor the provisions of section 69 are applicable. He submitted that the said amount was never received as the income of the assessee and the seized material also does not provide any such information. Therefore, the amount cannot be added and hence should be deleted. 40. The learned DR, on the other hand, heavy relied on the order

GANGADHARAN RENGANATHAN KOMAL,HYDERABAD vs. INCOME TAX OFFICER, WARD-14(1), HYDERABAD

In the result the appeal of the assessee is partly allowed

ITA 98/HYD/2024[2017-18]Status: DisposedITAT Hyderabad13 Mar 2024AY 2017-18

Bench: SHRI LALIET KUMAR (Judicial Member)

For Appellant: Shri P. Murali Krishna, C.AFor Respondent: Shri B. Yadagiri, Sr.AR
Section 142(1)Section 143(2)Section 143(3)Section 250Section 44ASection 68

66,660/-. 3.2. The appellant further challenges the revocation of section 68 by the AO stating that the identity

DCIT., CIRCLE 3(1), HYDERABAD vs. RATHNAMMA INFRATECH PRIVATE LIMITED, HYDERABAD

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

ITA 1235/HYD/2024[2022-23]Status: DisposedITAT Hyderabad07 Nov 2025AY 2022-23

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON'BLE (Accountant Member)

Section 142(1)Section 194H

Section 68 of the Income-tax Act, 1961. 8. Aggrieved with the order of Ld. CIT(A), the Revenue is now in appeal before the Tribunal. 11 Rathnamma Infratech Private Limited 9. Ms. U. Mini Chandran, the Ld. CIT-DR for the Revenue, submitted that, the Ld. CIT(A) erred in deleting the additions made by the A.O. towards

LAMPEX ELECTRONICS LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(1), HYDERABAD

In the result, appeal of the assessee is treated as partly allowed for statistical purposes

ITA 589/HYD/2020[2017-18]Status: DisposedITAT Hyderabad17 Oct 2022AY 2017-18

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Chary

For Appellant: Shri P.N.Moorthy, ARFor Respondent: Shri Kumar Aditya, DR
Section 115JSection 253(2)Section 36(1)(va)Section 68

66,572/-, by making the following additions/disallowances: Rs. 1. Disallowance under section 36(1)(va) r.w.s. 6,85,645 2(24)(x) of the Act 2. Disallowance of prior period expenditure 32,77,357 3. Unexplained cash credits under section 68

ACIT, CIRCLE-5(1), HYDERABAD vs. LAMPEX ELECTRONICS LIMITED , HYDERABAD

In the result, appeal of the assessee is treated as partly allowed for statistical purposes

ITA 96/HYD/2021[2017-18]Status: DisposedITAT Hyderabad17 Oct 2022AY 2017-18

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Chary

For Appellant: Shri P.N.Moorthy, ARFor Respondent: Shri Kumar Aditya, DR
Section 115JSection 253(2)Section 36(1)(va)Section 68

66,572/-, by making the following additions/disallowances: Rs. 1. Disallowance under section 36(1)(va) r.w.s. 6,85,645 2(24)(x) of the Act 2. Disallowance of prior period expenditure 32,77,357 3. Unexplained cash credits under section 68

VENU MYNENI,HYDERABAD vs. INCOME TAX OFFICER (INTERNATIONAL TAXATION)-II, HYDERABAD

In the result, the appeal of assessee is allowed

ITA 2094/HYD/2017[2010-11]Status: DisposedITAT Hyderabad22 Jun 2018AY 2010-11

Bench: Shri D. Manmohan & Shri B. Ramakotaiah

For Appellant: Shri P. Murali Mohan Rao, ARFor Respondent: Smt. B.K. Vishnu Priya, DR
Section 56(2)(vii)Section 68

68 are not applicable, they are to be added under section 69 of the I.T. Act. This does not invalidate the addition made in the absence of sources for the deposits. Therefore, entire addition made by the Assessing Officer is confirmed. In view of the above, ground nos. 2 to 7 are dismissed”. Contesting the above, assessee has raised

INCOME TAX OFFICER, WARD-1, KADAPA vs. PRITHAM & PRATHIK HOSPITALS PRIVATE LIMITED , KADAPA

In the result, the appeal of Revenue is partly allowed for statistical purposes

ITA 97/HYD/2019[2014-15]Status: DisposedITAT Hyderabad29 Nov 2022AY 2014-15

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2014-15 Income Tax Officer, Vs. M/S. Pritham & Prathik Ward – 1, Hospitals Pvt. Limited, Kadapa. Kadapa – 516002. Pan : Aahcp6013E. (Appellant) (Respondent) C.O.No.10/Hyd/2019 (In Ita 97/Hyd/2019) M/S. Pritham & Prathik Vs. Income Tax Officer, Hospitals Pvt. Limited, Ward – 1, Kadapa – 516002. Kadapa. Pan : Aahcp6013E. (Cross Objector / (Respondent) Appellant) Assessee By: Ms. S. Sandhya, Advocate. Revenue By: Ms. Swapna. Date Of Hearing: 24.11.2022 Date Of Pronouncement: 29.11.2022 Per Laliet Kumar, J.M. This Appeal By The Revenue & Cross-Objection By The Assessee Are Directed Against The Order Of Commissioner Of Income Tax (Appeals), Kurnool Dated 29.11.2018 For The Assessment Year 2014-15. 2. The Revenue Has Raised The Following Grounds :

For Appellant: Ms. S. Sandhya, AdvocateFor Respondent: Ms. Swapna
Section 133ASection 142(1)Section 143(3)Section 68Section 69

68 of the Act. (ii) SC decision in the case of P.K. Noorjahan in (1999) 103 taxman 32 is entirely in different context. In that case, the assessee, a young lady of 20 years, purchased certain lands and submitted that the investments were financed from out savings from the income of properties which were left by her step-father