IN THE HIGH COURT OF DELHI AT NEW DELHI
ITA 323/2008
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THE COMMISSIONER OF INCOME TAX XII ..... Appellant
Through:Mr.Sanjeev Sabharwal,Adv.
Versus
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SANDEEP KHANDELWAL ..... Respondent
Through
CORAM:
HON'BLE MR. JUSTICE MADAN B. LOKUR
HON'BLE MR. JUSTICE V.B. GUPTA
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O R D E R
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10.03.2008
The Revenue is aggrieved by an order dated 3rd August, 2007 passed by
the Income Tax Appellate Tribunal Delhi Bench ?F? relevant for the block period
1st April, 1996 to 4th April, 2002.
It appears that as a result of some search an envelope was found in the
office premises of the Assessee in which some amount was mentioned as returned.
The envelope bears the stamp of an organization called M/s Exim Consultant.
As a follow up investigation, the statement of one Rohit Nand, proprietor
of M/s Exim Consultant was recorded and though he admitted that the stamp
pertains to his concern but he did not having any dealing either with the
Assessee.
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There is nothing on record to suggest that the envelope had any
connection with the Assessee as found by the Tribunal. The hand writing was
neither of the Assessee nor his family members or any employee. There was
nothing on record to show that the amount was returned to any person nor there
is any mention of any name or date on the envelope etc. Under the
circumstances, the Tribunal upheld the view taken by the Commissioner of Income
Tax (Appeals) that it is not possible to link the Assessee with the envelope
and there was no possibility of adding any amount as undislosed income of the
Assessee.
We agree, on these facts, that the Assessee cannot be linked with the
envelope recovered from his office premises. The Tribunal has rightly deleted
the addition made by the Assessing Officer.
In view of the above, no substantial question of law is made out.
Dismissed.
MADAN B. LOKUR, J
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MARCH 10, 2008 V.B. GUPTA, J
Bisht
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