2004 (12) TMI 340

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....nce of cash at Rs. 6,57,642.60. The AO doubted this keeping of huge amount as physical cash balance in her custody as she has kept small amount of Rs. 1,84,180 in Canara Bank current account, Kelleys Branch. The AO, therefore, called for the explanation from the assessee for keeping this huge amount in her physical possession. The assessee explained that this amount was subsequently deposited in the bank and used for the purchase of property. The AO was of the opinion that there was no necessity to keep such amount of cash and even when this cash was in her possession, she has withdrawn money from various bank accounts and, therefore, doubted the availability of physical cash and treated this sum of Rs. 6,50,000 as income from other sources....

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....was saved by the assessee over a period of time. The assessee explained the total assets and liabilities position and he further submitted that the assessee has also filed return of income for the asst. yr. 1990-91. If the Department doubted the availability of cash balance, it can go to the concerned asst. yr. 1990-91 and treat it as unexplained income, but it cannot treat the opening balance in the asst. yr. 1991-92 as unexplained. The learned counsel for the assessee strongly supported the order of the CIT(A). 6. We have heard the rival submissions and perused the records. The assessee has filed a statement of affairs for the asst. yr. 1991-92 wherein she has shown the opening cash balance of Rs. 6,57,642.60. The AO added this physical ....