2019 (11) TMI 695

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.... Rs. 2,91,250/-. The case was selected for scrutiny and thereafter assessment was framed u/s 143(3) of the Act vide order dt.20.09.2016 and the total income was determined at Rs. 37,27,215/-. Aggrieved by the order of AO, assessee carried the matter before Ld.CIT(A), who vide order dt.09.07.2018 (in appeal No.87/2017-18) dismissed the appeal of the assessee. Aggrieved by the order of Ld.CIT(A), assessee is now in appeal and has raised the following grounds : "1. The learned CIT (A) erred in dismissing the appeal of the assessee without appreciating the facts of the case and failed to give adequate opportunities. 2. The Ld.CIT(A) erred in confirming the income assessed by the learned AO at Rs. 37,27,215/-. 3. The a....

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.... account in order to make payment by cheque for purchase of Parasailing Boats and contributions confirmed the same. 6. The appellant humbly submits that the concerned persons who contributed the sum could not get sufficient time to explain the source for the contribution raised by each of them which in unwarranted addition of Rs. 34,36,000/- in the hands of the appellant. 7. Without prejudice it is further submitted that although the concerned persons confirmed the contribution still the addition has been made, holding the failure to explain by the creditor, the source for the source, which was not justified as confirmed by the CIT(A). 8. The AO in the assessment proceedings sought an explanation about the source ....

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.... assessment order. With respect to the source of the deposits by those persons assessee submitted that the amount was received by them through hand loans. AO noted that the details of hand loans, names and address of the persons from whom hand loan was raised, whether the hand loan was returned by them or not etc. was not proved by the assessee. AO also noted that as per the bills issued by Aquarius Fibereglas Pvt. Ltd., the boat was purchased by the assessee along with Shri Umesh Sakharam Kasar and Shri Bharat Dashrath Belose. AO noted that the purchase was thus only in the name of these three persons and not other persons who stated to have contributed for the purpose of the boat. AO concluded that the persons who stated to have been cont....