2019 (1) TMI 1006

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....s to the confirmation of addition of Rs. 3,44,006/- out of the addition made by the AO. 3. Facts of the case in brief are that in this case action under section 132(2) of the Income Tax Act, 1961 was carried out on 27.12.2011. The response the assessee filed the reutn of income on 29.2.2012 declaring taxable income of Rs. 60,15,128/-. During the course of assessment proceedings, the AO noticed that on 27.12.2011 during Punjab Assembly Election cash amounting to Rs. 6,00,000/- was seized from the assessee near Phillaur for which satisfactory reply / evidence regarding the source was not given. The AO asked the assessee to explain the source of above cash seized. In response the asseessee submitted that it was out of the cash in hand, he fur....

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....ppellant. The appellant has not been able to bring on record any further evidence to substantiate his explanation. The supporting evidence filed by the appellant has failed to substantiate even the existence of the party to whom cash sale was made. AO has rejected the contention of the appellant that cash sale on that date was made and to that particular party namely M/s Ubhi Agro Industries. The judicial decisions cited by the appellant are found to be distinguishable on account of peculiar facts of this case. Therefore, I hold that AO was justified in treating the amount of Rs. 3,44,006/- as unexplained cash. Accordingly, I confirm the addition of Rs. 3,44,006/- made by the AO under this head." 5. Now the assessee is in appeal. 6. The l....