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Reassessment initiated on specific Investigation Wing information about substantial cash deposits was sustained where the Assessing Officer examined the information and formed a belief that income had escaped assessment. Recording cash receipts as sales did not by itself establish that corresponding bank deposits arose from business sales; reliable linkage among the sales, stock movement and deposits was required to rebut an unexplained cash-credit addition. A challenge to mere initiation of penalty proceedings was premature, while interest levied consequentially on the assessment followed the assessment outcome.
Reassessment initiated on specific Investigation Wing information about substantial cash deposits was sustained where the Assessing Officer examined the information and formed a belief that income had escaped assessment. Recording cash receipts as sales did not by itself establish that corresponding bank deposits arose from business sales; reliable linkage among the sales, stock movement and deposits was required to rebut an unexplained cash-credit addition. A challenge to mere initiation of penalty proceedings was premature, while interest levied consequentially on the assessment followed the assessment outcome.
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