2020 (1) TMI 1015

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....mostly industrial and private clients. Assessee filed its return of income for A.Y. 2013-14 on 28.09.2013 declaring total income of Rs. 2,97,31,804/-. The case was selected for scrutiny and thereafter, assessment was framed u/s 143(3) of the Act vice order dated 29.03.2016 and the total income was determined at Rs. 5,31,46,451/-. Aggrieved by the order of AO, assessee carried the matter before Ld.CIT(A), who vide order dated 30.01.2017 (in appeal No.CIT(A), Pune-1/10278/2016-17) granted partial relief to the assessee. Aggrieved by the order of Ld.CIT(A), assessee is now in appeal before us and has raised the following grounds : "1. The ld CIT (A) has erred in confirming the addition of Rs. 15,57,000/- u/s 68 of the Act made by the AO only....

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....eposits in the bank account of lender Mr. Uttam Chordiya before the issue of cheque of share application money and unsecured loans (the details of which are tabulated by the AO in page 9 of the order). The assessee was therefore asked to furnish the source of cash deposits and the availability of the cash. Assessee inter-alia submitted that the cash was deposited from the cash balance available in his banks. The submissions of the assessee were not found acceptable to the AO. AO noted that no details as to whether the books of accounts were maintained by Mr. Uttam Chordiya, though he was a salaried employee was not clarified by the assessee. The submission of the assessee of having cash deposits out of the cash withdrawals were also not fou....

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....appreciated that Mr. Uttam Chordiya though a different entity is not a third party in real sense. In a private limited company the role of Director is no different than partner of a firm and therefore, the source of cash deposit in the bank account of Mr. Uttam Chordiya could have been easily explained had the appellant wanted to. This has not been explained for the obvious reason that there was no plausible explanation regarding the source of cash deposit. Accordingly, I do not find any merit in the submission of the appellant and the action of the AO in making addition of Rs. 15,57,000/- is upheld. Thus, the ground is dismissed." Aggrieved by the order of Ld.CIT(A), assessee is now before us. 5. Before us, Ld.A.R. reiterated the submis....