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INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
ANUBHAV SHARMA, J, MANISH AGARWAL, AM
SANJAY TANEJA NEW DELHI – Appellant
Versus
ACIT CENTRAL CIRCLE-18 NEW DELHI – Respondent
| Table of Content |
|---|
| 1. factual background of the appeal. (Para 1 , 2 , 3 , 4 , 5) |
| 2. assessee's arguments against additions. (Para 6 , 7 , 8 , 9) |
| 3. court's observations on evidence presented. (Para 10 , 11 , 12 , 14 , 15) |
| 4. analysis of legal definitions and implications. (Para 16 , 18 , 19) |
| 5. court's conclusive reasoning on 'dumb documents'. (Para 24 , 26) |
| 6. final judgment on the appeal. (Para 27 , 28 , 32) |
ORDER
PER MANISH AGARWAL, AM :
The present appeal is filed by the assessee against the order dated 20.05.2022 passed by Ld. Commissioner of Income Tax (A)- 27, New Delhi [CIT(A), in short] in Appeal No. CIT(A), Delhi- 27/10015/2019-20 u/s 250 of the Income Tax Act, 1961 [“the Act”] arising from the assessment order dated 29.03.2019 passed u/s 254/143(3) of the Act pertaining to Assessment Year 2010-11.
2. Brief facts of the case are that a survey operation u/s 133A of the Act was carried out at the business premises of the assessee wherein cash of INR 76,24,000/- was found. As the assessee did not explain the source of such cash, search proceedings were initiated u/s 132 of the Act at the business and residential premises of the assessee. Thereafter, the assessee has filed the return
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