HIGH COURT OF PUNJAB AND HARYANA
Harbhajan Singh
versus
Commissioner of Income-tax-II, Chandigarh
IT Appeal No. 17 of 2012
May 7, 2012
JUDGMENT
Ajay Kumar Mittal, J
This appeal has been filed by the assessee under Section 260A of the Income Tax Act, 1961 (in short “the Act”) against the order dated 27.9.2011 passed by the Income Tax Appellate Tribunal, Chandigarh Bench ‘A’, Chandigarh (hereinafter referred to as “the Tribunal”) in ITA No. 432/CHD/2011 for the assessment year 2007-08 claiming the following substantial questions of law:-
“A. Whether the ITAT is justified in directing the AO to take the rate of Rs. 600/- against Rs. 428/- shown by the assessee and arbitrarily adopted at Rs. 800/- by the AO merely on the uncorroborated statement of a low-paid employee?
B. Whether the order of the Tribunal is perverse as it has failed to appreciate that the discrepancies found at the time of survey were later on reconciled and to the extent of reconciliation, the additions ought not to have been upheld?”
2. Briefly stated the facts necessary for adjudication of the present appeal are that on 20.3.2007, a survey under Section 133A of the Act was conducted at the business premises of the assessee. During survey, the assessee surrendered Rs.50 lacs as under:-
