TaxTMI 
TaxTMI 
2021 (4) TMI 1122
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....se from the CIT(A)-3, Visakhapatnam's separate orders; all dated 31.3.2018, for assessment years 2005-06, 2006-07, 2009-10 and 2010-11 in case nos. 500 to 504/2017-18; respectively. The latter assessee's sole appeal ITA 1072/H/18 is directed against the very CIT(A)'s order dated 12.03.2018 passed in case no. 499/2017-18 for assessment year 2010-11. Relevant proceedings in all these cases are u/s. 143(3) r.w.s 153A of the Income Tax Act, 1961; in short 'the Act'. Heard both the assessees through Shri B. Ramakrishnan (FCA) and Smt. N. Biswas; learned CIT-DR appearing for assessees and Revenue; respectively. 2. We proceed to the former assessee's appeals ITA 1068 to 1071/H/18 for AY 2005-06, 2006-07, 2009-10 and 2010-....
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.... well. This assessee's appeal ITA 1069/H/18 is also declined. 4. We now move to AY 2009-10 involving assessee's appeal 1070/Hyd/18 challenging correctness of both the lower authorities action adding alleged unexplained liability of Rs. 12 lakhs. It emerges during the course of hearing that the impugned sum represents three alleged promissory notes; all dated 18.03.2009 in the names of Shri J.N. Chandra Reddy, J. Madhumalathi and J.N. Shanthi involving sum of Rs. 5 lakhs in former two cases and Rs. 2 lakhs in the last instance; respectively. We notice that the search in question had found and seized those original promissory notes than photocopies thereof which sufficiently indicates that the corresponding loan transactions had not ....
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....abu. He shall further ensure that the assessee is granted telescoping benefit of the corresponding unaccounted receipts amount of Rs. 30 lakhs in AY 2005-06 & sundry creditors addition of Rs. 14,01,000/- (supra) against the unaccounted interest payment addition in the impugned assessment year 2010-11 as per law. Necessary computation shall follow. This last appeal ITA 1071/H/18 is partly accepted in foregoing terms. 6. We are now left with latter assessee's appeal ITA 1072/H/18 for AY 2010-11 seeking to reverse both the lower authorities action adding a sum of Rs. 9,43,703/- as unexplained cash credits. The CIT(A) has discussed this entire issue as under: "4. I have carefully considered the grounds raised in the appeal, written submi....
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....ments of the appellant and findings of the Assessing Officer in the assessment order. The Assessing Officer has not disputed that the appellant is in the business of money lending. It is seen from the return of income that the appellant has been showing the interest income. The Assessing Officer has treated the entire deposits as unexplained cash credits of the appellant probably keeping the provisions of Section 68 in the mind. 4.4. During the appellate proceedings. the appellant has argued that the sources for the deposits are her past savings. However, no proof was adduced before me to substantiate her claim. In all fairness, the Assessing Officer has given credit for Rs. 91,144/- and taxed at Rs. 9,43,730/- I do not find any reason to....