INCOME TAX APPELLATE TRIBUNAL (CHANDIGARH BENCH)
JATIN GARG CHANDIGARH – Appellant
Versus
ASSTT. COMMISSIONER OF INCOME TAX CC-2 CHANDIGARH – Respondent
| Table of Content |
|---|
| 1. details of the loan transaction and evidence of assessment. (Para 3 , 4) |
| 2. assessee's arguments regarding the explanation of loan transactions. (Para 5 , 8 , 11 , 19) |
| 3. procedural and evidential challenges faced by the assessee. (Para 6 , 7 , 12 , 15) |
| 4. court's reasoning on the failure to apply section 69 correctly. (Para 24 , 25 , 27 , 28 , 29) |
| 5. final decision of the court favoring the assessee. (Para 30) |
आदेश/Order
PER VIKRAM SINGH YADAV, A.M. :
This is an appeal filed by the Assessee against the order of the Ld. CIT(A)-3, Gurgaon dt. 27/09/2024 pertaining to Assessment Year 2018-19.
2. In the present appeal, the Assessee has challenged the action of the ld CIT(A) in upholding the additions made by the Assessing officer of Rs. 5,00,00,000/- received from Sh. Gurinder Singh as loan on surmises and conjectures.
3. Briefly the facts of the case are that the assessee filed his return of income under Section 139(1) on 18/07/2018 at the total income of Rs. 3,11,370/-. Consequent upon search under section 132(1) of the Act, notice under section 143(2) dt. 17/09/2019 was issued and served upon the assessee. Thereafter notice under section 142(1) alongwith questionnaire wer

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