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The Principal Commissioner Of Income ... vs M/S Ram Krishnan Kulwant Rai Holdings ... on 29 October, 2021

CIT vs. Kulwant rai in 291 ITR 36 (Delhi High Court) "16. This cash flow statement furnished by the assessee was rejected by the AO which is on the basis of suspicion that the assessee must have spent the amount for some other purposes. The orders of AO as well as CIT(A) are completely silent as to for what purpose the earlier withdrawals would have been spent. As per the cash book maintained by the assessee, a sum of Rs. 10,000 was being spent for household expenses every month and the assessee has withdrawn from bank a sum of Rs. 2 lacs on 4th Dec., 2000 and there was no material with the Department that this money was not available with the assessee. It has been held by the Tribunal that in the instant case the withdrawals shown by the assessee are far in excess of the cash found during the course of search proceedings. No material has been relied upon by the AO or CIT(A) to support their view that the entire cash withdrawals must have been spent by the assessee and accordingly, the Tribunal rightly held that the 15 ITA No.337 & 341/DEL/2023 assessment of Rs. 2.5 lacs is legally not sustainable under s. 158BC of the Act and the same was rightly ordered to be deleted..."
Supreme Court - Daily Orders Cites 0 - Cited by 19 - Full Document

Kanpur Steel Co. Ltd. vs Commissioner Of Income-Tax, Uttar ... on 18 February, 1957

Kanpur Steel Co. Ltd. Vs CIT; [1957] 32 ITR 56 (ALL. HC) "...Section 69Aof the Income-tax Act, 1961 [Corresponding to section 23 of the Indian Income-tax Act, 1922] - Unexplained money etc. - Assessment year 1948-49 - In pursuance of High Denomination Bank Notes (Denomination) Ordinance, 1946, assessee-company exchanged 32 high denomination notes - Regarding source of these high denomination notes, assessee claimed that these notes represented part of its cash balance - ITO, however, rejected claim of assessee and held that amount represented by those currency notes was suppressed income of assessee - Tribunal, though did not find assessee's explanation to be false, yet it deleted only a part of amount added back by ITO as income from undisclosed sources - Whether when assessee-company had given an explanation which was reasonable, revenue authorities could treat amount in question as income from undisclosed sources only if there was some other material from which such inference could have been drawn
Allahabad High Court Cites 3 - Cited by 35 - Full Document
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