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3.4 In view of the above discussion, income of Rs.10,50,00,000/- surrendered by the assessee u/s 132(4) of the I.T.Act is assessed as undisclosed income u/s 69A of the Act. This issue attracts Penalty u/s 271AAA of the I.T. Act, 1961 as the assessee fails to substantiate the manner in which the undisclosed income was derived."

4. Aggrieved the assessee filed appeals before Ld. CIT(A). The Ld. CIT(A) deleted the above additions by holding similar findings in respect of these two years. For the sake of convenience, the findings for Asst. Year: 2010-11 are reproduced below.