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Issues: Whether the addition of cash deposit of Rs. 15 lakh sustained by the first appellate authority required interference or restoration to the Assessing Officer for fresh examination in view of the assessee's explanation and additional evidence.
Analysis: The assessee sought to explain the remaining cash deposit by referring to loans from friends and relatives and regular agricultural income. Affidavits supporting the claim were produced before the Tribunal for the first time and were treated as additional evidence. Considering the assessee's status as a senior citizen, retired government servant, and agriculturist, the Tribunal found it appropriate to examine the source of the disputed deposit afresh at the assessment stage. The Tribunal also directed that reasonable opportunity be granted to furnish supporting material in the set aside proceedings.
Conclusion: The matter relating to the addition of Rs. 15 lakh was restored to the Assessing Officer for fresh adjudication, and the assessee's grounds were allowed for statistical purposes.