Cash deposit addition sent back for fresh verification after inadequate inquiry and denial of proper opportunity.

Cash deposits in the assessee's bank account, claimed to be sale proceeds of agricultural land, were not finally sustained because the record showed inadequate verification of the issue. The Tribunal restored the matter to the Assessing Officer for fresh adjudication, with directions to grant the assessee a reasonable opportunity of hearing in the set-aside proceedings. The addition was therefore sent back for de novo consideration rather than confirmed on the existing material.

---

---

Issues: Whether the addition made on account of cash deposits and the related assessment required reconsideration in view of the alleged lack of verification and denial of proper opportunity.

Analysis: The dispute centred on cash deposits in the assessee's bank account claimed to represent sale proceeds of agricultural land. The assessment and appellate orders had sustained the addition, but the material before the Tribunal showed that the issue had not been examined with adequate verification from the revenue side. In these circumstances, and with the consent of both sides, the matter was restored to the Assessing Officer for fresh adjudication. The Tribunal directed that the assessee be afforded a reasonable opportunity of hearing in the set-aside proceedings.

Conclusion: The addition was not finally sustained at this stage and the issue was sent back to the Assessing Officer for de novo consideration after giving the assessee a proper opportunity.

---