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INCOME TAX APPELLATE TRIBUNAL (BANGALORE BENCH)
Laxmi Prasad Sahu, Accountant Member, Keshav Dubey, Judicial Member
Rajnish Gopinath – Appellant
Versus
ADIT, Range –1, Bangalore – Respondent
| Table of Content |
|---|
| 1. search revealed cash; penalty initiated for s.269st violation. (Para 2 , 3) |
| 2. broad interpretation of 'receive' under s.269st includes custody. (Para 4) |
| 3. statements u/s 132(4) binding; belated retraction rejected. (Para 5 , 6 , 7 , 8 , 9 , 10) |
ORDER
Per Laxmi Prasad Sahu, Accountant Member :
This appeal is filed by the assessee against the Order passed by the learned CIT(A) - 11, vide DIN and Order No.ITBA/APL/M/250/2024- 25/1067130031(1) dated 30.07.2024, on the following grounds of appeal:
1. The order of the Learned Commissioner of Income Tax (Appeals)- 11, Bengaluru. in so far as the same is against the appellant, is opposed to law, weight of evidence, probabilities, facts and circumstances of the Appellant's case.
2. The Learned CIT(A) erred in not considering that the Penalty Order passed by the Additional Commissioner of Income Tax was in contradiction to the Assessment order approved by the same Additional Commissioner of Income Tax.
3. The Learned CIT(A) erred in holding that the amount given for safe custody is an amount received by the Appellant coming within the scope of Section 269ST of the Income Tax Act.
4. The Learned CIT(A) erred in not considering t
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