Prakash Gupta,J. - (1.) The appellant, in this appeal under Section 260A of Income Tax Act, 1961 questions the concurrent findings of fact rendered by the Lower Appellate Authorities which had endorsed the A.O's addition made in the course of search assessments under Section 153(A).
(2.) The assessee's premises-as well as those of others were searched on 12.10.2011. Certain incriminating documents were seized; these included a document termed as Ikrarnama. The assessee's statement too was recorded in the course of the search proceedings. The A.O. acting on the materials recovered and statement made; brought to tax an amount of Rs. 20 lakhs, inter alia in the hands of the assessee under Section 68 of the Act. The assessee unsuccessfully appealed contending that the document on the basis of which the petition was made, did not categorically record that any amount was invested by him. It was also urged that so called one Mr. Jagdish Panjwani, alleged owner of the mine, in fact was not the owner of the mine, which was the alleged basis of the partnership. Both the CIT(A) and later on the ITAT, rejected there submissions.
(3.) Learned counsel relied upon the statements made (which are abstracted as part of the CIT's order) and the fact that Jagdish Panjwani was not the owner of the mines. It was also stated that the assessee too was not the owner of the mine, nor had he invested any amount and the inference drawn by the ITAT was, therefore, perverse and contrary to the facts.;