2020 (9) TMI 1043

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....e following grounds of appeal : 1. On the facts and circumstances of the case, order of the learned Commissioner of Income Tax (Appeals)-4 dated 22/03/2019, for the AY-2011-12 is not maintainable in law. 2. On the facts and the circumstances of the case learned Commissioner of Income Tax (Appeals) failed to appreciate that, with regard to the cash investment by the appellant for purchase of the land, with regard to the source of income investment was furnished, but without considering the same order passed by the Assessing Authority the same was uphld by CIT(A) is against the principle of natural justice. 3. On the facts and circumstances of the case, the learned Commissioner of Income Tax (Appeals) erred in confi....

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....are that, the assessee company is engaged in the business of acquisition of land, conversion, formation of approved layout and sale of lands. During the financial year as per CIB information, the assessee company has made cash deposits in the bank account maintained with Royal Bank of Scotland, Residency Road, Bangalore. The assessee company has not filed the return of income for the Asst. Year 2011-12, therefore the assessing officer has initiated reassessment proceedings under Section 147 of the Act and issued notice under section 148 on 31.3.2018. Since there was no response to notice u/sec148 of the act, the assessing officer has issued summons under Section 131 of the Act to the director of the assessee Company and the statement was re....

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....r assessee failed to substantiate with evidence,that the amounts deposited in the bank account represents the advances returned back from builders. Finally the LdCIT(A) confirmed the action of the Assessing Officer and dismissed the assessee's appeal. Aggrieved by the order of CIT (Appeals), the assessee has filed appeal before the Tribunal. 4. At the time of hearing, the learned Authorized Representative submitted that the CIT (Appeals) has erred in ignoring the facts, that the cash deposits made in Royal Bank of Scotland are supported with sources, which includes Rs. 74,00,000/- pertaining to Land advances returned by the farmers and Rs. 6,21,000/- was deposited out of the opening balance on hand and Rs. 9,65,000/- are the depos....