Kumar Suman Singh Vs ACIT (ITAT Patna)
ITAT Patna held that addition towards unexplained income upheld since assessee failed to prove genuineness of transaction and creditworthiness. Accordingly, appeal dismissed and addition upheld.
Facts- The assessee is an individual. A search and seizure operation u/s 132(1) of the Act was conducted on 19.02.2004 in the case of the assessee as well as his associates/relatives. In this search operation, substantial investments in form of movable and immoveable properties were discovered which was alleged to have been unaccounted income of the assessee. The investigation revealed significant undisclosed income from activities related to examinations and recruitment process such as pre-medical exams, Bank P.O exams etc.
Accordingly, AO initiated proceedings u/s 153A of the Act and due notices were issued to the assessee requiring to file returns. Thereafter, AO completed the assessment for the relevant year by determining substantial undisclosed income. Subsequent to the assessment, it was found that the assessee had used multiple alias names such as Indrajeet Kumar (Singh) and Ranjit Singh. Later on, income was assessed in the name of Indrajeet Kumar and merged with the assessed income of the assessee which was ultimately brought to tax by AO as there was no separate existence for different proceedings were found by AO.
