Growth Avenue Ltd.,, Surat vs Assessee
The assessee also relied on the
decision of ITAT Amritsar Bench in the case of Rajesh Mehta (supra). The
presumption u/s.132(4) cannot be resorted to since no evidence was found in
the possession of the assessee. It was further argued that promissory notes
were not found in the possession of assessee and hence provisions of Section
132(4A) were not applicable to the assessee in this regard.