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6. Both the authorities below committed an error in holding that RS.50,00,000/- received on behalf of M/s. Jewel Associates with respect to Mallasandra properties has been agreed to be disclosed as undisclosed income for A.Y. 2005-06, presumption should be drawn in respect of other entries.

7. Both the authorities below committed an error in failing to appreciate that both the orders is based on presumption, assumptions and innuendos of dummy tally entries without furnishing the entire set of account of dummy tally entries, the settlement worked out by Mr. Dayanand Pai before the Settlement Commission, the corresponding reply given by the revenue which would enable the assessee to give a suitable reply and without any evidence of receipt of the amounts reflected in the dummy tally entries by the assessee.

7. Both the authorities below committed an error in failing to appreciate that both the orders is based on presumption, assumptions and innuendos of dummy tally entries without furnishing the entire set of account of dummy tally entries, the settlement worked out by Mr. Dayanand Pai before the Settlement Commission, the corresponding reply given by the revenue which would enable the assessee to give a suitable reply and without any evidence of receipt of the amounts reflected in the dummy tally entries by the assessee.

6. Both the authorities below committed an error in holding that RS.50,00,000/-received on behalf of M/s. Jewel Associates with respect to Mallasandra properties has been agreed to be disclosed as undisclosed income for A.Y. 2005-06. presumption should be drawn in respect of other entries.

7. Both the authorities below committed an error in failing to appreciate that both the orders is based on presumption, assumptions and innuendos of dummy tally entries without furnishing the entire set of account of dummy tally entries, the settlement worked out by Mr. Dayanand Pai before the Settlement Commission, the corresponding reply given by the revenue which would enable the assessee to give a suitable reply and without any evidence of receipt of the amounts reflected in the dummy tally entries by the assessee.

6. Both the authorities below committed an error in holding that RS.50,00,000/- received on behalf of M/s. Jewel Associates with respect to Mallasandra properties has been agreed to be disclosed as undisclosed income for A.Y. 2005-06, presumption should be drawn in respect of other entries.

7. Both the authorities below committed an error in failing to appreciate that both the orders is based on presumption, assumptions and innuendos of dummy tally entries without furnishing the entire set of account of dummy tally entries, the settlement worked out by Mr. Dayanand Pai before the Settlement Commission, the corresponding reply given by the revenue which would enable the assessee to give a suitable reply and without any evidence of receipt of the amounts reflected in the dummy tally entries by the assessee.