(1.) THIS appeal has been preferred by the Revenue against the order of the CIT -III, Delhi dt. 1st Dec., 2011 in Appeal No. 715/2010 -11 for asst. yr. 2006 -07. The sole ground raised by the Revenue in this case reads as under:
(2.) BRIEFLY stated the facts giving rise to this appeal are that a search and seizure operation under s. 132 of the IT Act, 1961 (for short the Act) was carried out at the residential premises of the appellant (sic - -respondent) on 15th Jan., 2009. Consequent upon the search and seizure operation, a notice under s. 153A of the Act was issued on 30th July, 2009 to file return and in response, the appellant (sic - -respondent) filed a return on 26th March, 2010 declaring income of Rs. 16,01,567. The AO completed the assessment under s. 153A r/w s. 143(3) of the Act at an income of Rs. 4,63,01,570 vide order dt. 27th Dec, 2010, thereby making an addition of Rs. 4,47,00,000 on account of undisclosed income under s. 69 of the Act on the basis of certain written pages containing rough noting found during the course of search and seizure from the residence of the assessee appellant (sic - -respondent).
(3.) THE AO rejected the submissions and explanation offered by the assessee with regard to Annexure A -1 and made an addition of Rs. 4,47,00,000 under s. 69 of the Act with following observations and findings: