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Generate professional replies to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.

Step 1 – Issue Identification & Review

The AI analyses your query, notice, order, or uploaded documents and identifies the key issues involved.

• Review the issues identified by the AI
• Add, edit, remove, or refine issues as required


Step 2 – Draft Generation

Once you approve the issues, the AI performs issue-wise legal research and prepares a structured draft response.

• Relevant statutory provisions
• Judicial precedents and Supreme Court, High Court and other citations
• Issue-wise legal analysis
• Practical arguments and supporting content
• Professionally structured draft ready for further review.

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2018 (5) TMI 1004

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....a common order is passed for the sake of convenience. 2. The assessee filed these appeals with a delay of 45 days. To this effect, assessee filed a petition for condonation of the said delay wherein she stated that she has shifted her residence to Bangalore to look after her ill mother due to which the delay occurred in filing the appeals after discussing the issues in detail with her advocate who is stationed at Hyderabad. She further stated that the delay is for the reasons beyond her control and is not intentional. Considering the submissions of the assessee and the objection of the ld. DR, we hereby condone the delay as the assessee was prevented by reasonable cause in not f iling the appeals within the stipulated t ime. 2. Briefl....

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....which was increased to Rs. 1.25 lakh during October, 2009 and further increased to Rs. 1.5 lakh per month in the month of December, 2010. However, as per your calculation sheet you have received 3 lakhs per month. During 2008, which is increased to Rs. 3.25 lakhs per month from October, 2009 onwards and to Rs. 3.5 lakhs per month from December, 2010 onwards. Ans. I have received Rs. 2 lakhs per month in cash apart from my regular salary from March, 2008 onwards. This Rs. 2 lakhs reflected in my bank account with Dhana Lakshmi Bank, Nellore as cash deposit. 2.2 AO observed that in the return of income submitted for the AY under consideration, the assessee has not offered the cash portion of salary of Rs. 24,00,000/- which is rece....

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....the corresponding deposits in the bank account. The assessee failed to submit the statement of affairs for the AY under consideration. In the absence of a satisfactory reply by the assessee, the AO concluded that the assessee does not want to offer any explanation in respect of unaccounted salaries. Therefore, he added an amount of Rs. 24,00,000/- as unexplained cash credit u/s 68 of the Act. 3. Aggrieved by the order of AO, the assessee preferred an appeal before the CIT(A). 4. The CIT(A) passed a consolidated order from AY 2006-07 to 2012-13. As regards the said addition of Rs. 24,00,000/- as unexplained cash credit u/s 68 of the Act, the CIT(A) confirmed the same in the AYs under consideration by observing as under: "08.4 ....

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....orrect. The additional income correctly chargeable to tax should, therefore, be Rs. 2 lakhs in AY 2008-09 and Rs. 24 lakhs in each of the AYs from 2009-10 to 2012-13." 5. Aggrieved by the order of CIT(A), the assessee is in appeal before us challenging the action of the CIT(A) in confirming the addition of Rs. 24,00,000/- u/s 68 of the Act made by the AO in the appeals under consideration. 6. Ld. AR submitted that the assessee is a Doctor employed at Narayana Hospital. There was search in the case of Narayana Educational Society at Nellore on 03/08/2011 and consequent to search, the premises of the assessee was also searched and a statement u/s 132(4) was recorded. In such statement, assessee has disclosed salary income received by he....

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....in AY 2009-10 - Rs. 7,32,520/-, in AY 2010-11 - Rs. 23,02,2010/-, in AY 2011-12 - Rs. 55,79,680/- and in AY 2012-13 - Rs. 21,40,450/-. After the search, the known source of income to assessee are, salary income (official), professional income in cash and interest from bank. There is no other source of income either disclosed by the assessee or unearthed by the department. Therefore, the income of the assessee cannot be more than the above three sources of income. On careful reading of the cash flow statement and bank statement submitted by the assessee, we find that there are cash deposits in the bank of Dhanalakshmi, Nellore to the extent of Rs. 2 lakhs per month in AY 2012-13 and no regular deposits in AY 2009-10 and 2010-11. However, we ....