residence was of business concern of the
assessee.
ll. Neither sec. 69A nor sec. 69B attracted
i) AO & CIT(A) have invoked sec ... Addition confirmed b Remarks
AO Id. CIT A
Sec. (IQs.) sec. (Rs.)
Unexplained 69B 6,23,94,369/- 69A 4,91,16,136/-
stock
assessee includes any income
referred to in section 68 , section 69 , section 69A , section 69B , section 69C or
section 69D , the income-tax payable shall ... calculated on the income referred to in
section 68 , section 69 , section 69A , section 69B , section 69C or section
69D , at the rate of thirty
assessee includes any income
referred to in section 68 , section 69 , section 69A , section 69B , section 69C or
section 69D , the income-tax payable shall ... calculated on the income referred to in
section 68 , section 69 , section 69A , section 69B , section 69C or section
69D , at the rate of thirty
assessee includes any income
referred to in section 68 , section 69 , section 69A , section 69B , section 69C or
section 69D , the income-tax payable shall ... calculated on the income referred to in
section 68 , section 69 , section 69A , section 69B , section 69C or section
69D , at the rate of thirty
assessee includes any income
referred to in section 68 , section 69 , section 69A , section 69B , section 69C or
section 69D , the income-tax payable shall ... calculated on the income referred to in
section 68 , section 69 , section 69A , section 69B , section 69C or section
69D , at the rate of thirty
book or as physically and as such the
provisions of section 69B are not applicable at all.
3. The Appellant crave liberty to add, amend ... figures, the onus is on the appellant to prove the same.
Section 69B of the Act provides that the assessee should explain the source
book or as physically and as such the
provisions of section 69B are not applicable at all.
3. The Appellant crave liberty to add, amend ... figures, the onus is on the appellant to prove the same.
Section 69B of the Act provides that the assessee should explain the source
income of the
nature referred to in section 68 , section 69 , section 69A , section 69B , section 69C or
section 69D , the tax cannot be charged ... said allegation itself, no addition is warranted u/s Section 68 , 69 , 69A or 69B, 69C, 69D of
the Act. It is clear that section
Section 115BBE
115BBE . (1) Where the total income of an assessee,-
(a) includes any income referred to in section 68 , section 69 , section69A ,
section 69B ... under section 139 ; or
(b) determined by the Assessing Officer includes any income referred to in
section 68 , section 69 , section 69A , section 69B , section
made by AO on
account of alleged unexplained investment invoking sec. 69B . The addition
made by AO and confirmed by Ld. CIT(A) is arbitrary ... account of alleged excess stock found during search invoking sec. 69B . The
addition made by AO and confirmed by Ld. CIT(A) is illegal
