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The Appellate Tribunal considered the issue of reopening assessment u/s 147 and estimation of income from cash deposits u/s 69A. The Tribunal noted that the assessee failed to comply with notices explaining the source of deposits. The CIT(A) mentioned that returns were filed after receiving notice u/s 148, but there was no evidence that the returns were treated as non-est by the AO. The assessee did not provide necessary details to the AO due to business cessation and joining government service. The Tribunal found that the assessee had filed returns for previous years and directed the AO to apply a net profit rate of 15% on total deposits for taxation, partially allowing the appeal.
The Appellate Tribunal considered the issue of reopening assessment u/s 147 and estimation of income from cash deposits u/s 69A. The Tribunal noted that the assessee failed to comply with notices explaining the source of deposits. The CIT(A) mentioned that returns were filed after receiving notice u/s 148, but there was no evidence that the returns were treated as non-est by the AO. The assessee did not provide necessary details to the AO due to business cessation and joining government service. The Tribunal found that the assessee had filed returns for previous years and directed the AO to apply a net profit rate of 15% on total deposits for taxation, partially allowing the appeal.
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