Shivam Leasing Pvt Ltd Vs ITO (ITAT Delhi)
ITAT Delhi held that addition under section 69A on account of income from undisclosed source sustained in assessee deliberately failed to produce all the books of accounts and no material evidence furnished by the assessee.
Facts- The assessee filed its return of income on 29.09.2008 which was processed u/s 143(1) of the Income-tax Act, 1961. Subsequently, on the basis of information that assessee company had introduced unaccounted money in its books of accounts during F.Y. 2007-08 relevant to A.Y. 2008-09, the assessment was reopened u/s 147 of the Act.
In response to notice u/s 148 of the Act the assessee submitted that return of income filed on 29.02.2016 may be treated as its return of income filed against notice u/s 148 of the Act. Considering the submissions furnished on behalf of assessee during assessment proceedings the AO completed the assessment u/s 147 r.w.s. 143(3) of the Act at Rs. 1,05,31,500/- by adding Rs. 1,05,18,095/- on account of income from undisclosed sources.
CIT(A) dismissed the appeal. Being aggrieved, the present appeal is filed.
Conclusion- Held that after carefully going through the order of learned CIT(A) we find that in confirming the impugned addition of Rs. 1,05,31,500/- made by the AO the learned CIT(Appeals) has duly examined the explanation offered by the assessee and has given categorical finding that assessee deliberately failed to produce all books of accounts during the assessment proceedings. No material evidence to the contrary has been filed by the assessee. Therefore, we do not find any reason to interfere in the finding of learned CIT(A).
