COMMISSIONER INCOME TAX Vs. DILBAGH RAI ARORA

JUDGEMENT

(1.) The present appeal has been filed under Section 260A of Income Tax Act, 1961 arising out of order dated 27.2.2009 passed by Income Tax Appellate Tribunal, Lucknow Bench 'A', Lucknow in ITA No. 658/Luc/2008 for the assessment year 2006-2007. The aforesaid appeal was admitted by this Court on 6.12.2012 on the following questions of law-

(2.) On 1.9.2005, the business premises and residence of the respondent-assessee was searched. During the course of search operation cash, jewellery and other valuables were found and seized. On 30.10.2006, the respondent-assessee filed its return and declared its income of Rs. 24,05,86,630/-. Thereafter, notices under Section 143(2) and 142(1) were issued on 2.7.2007 and 5.11.2007 and questionnaires were issued on 14.12.2007 and 17.12.2007. In response to the notice and questionnaires, the detailed written replies were submitted and case was also discussed in detail with representative of Assessee.

(3.) On 6.10.2005 the statement on oath of assessee-respondent was recorded under Section 132(4) in which he has offered to surrender a sum of Rs. 31 Crores for taxation for the Assessment Year 2006-07.