2021 (2) TMI 1254

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.... in the circumstances of the case and in law, Ld.CIT(A) erred in sustaining the reopening action of AO under section 147 to 151 because stand alone Annual Information Return (AIR) data is not valid to believe that income has escaped assessment accordingly confirming addition of Rs. 3,17,600/- on account of cash deposited in saving bank account is not sustainable in the eye's of law. 1.2. That on the facts and in the circumstances of the case and in law, the appellant submits that 'reason to believe' was recorded by AO under suspicion and fallacious assumption that cash deposited in savings bank account constitute income of assessee and accordingly reassessment proceedings under section 147 is without jurisdiction and de....

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....ted from the past savings and receipt of cash from wife. 3. The assessee himself denies his liability towards interest charged u/s 234A, u/s 234B and u/s 234C and prays for appropriate relief. 4. That the above grounds are independent and without prejudice to each other. The assessee craves the right to amend, add, delete, replace, all or any of the grounds of appeal either during the course of hearing or at any time before hearing of this appeal" 2. The only effective ground in this appeal is against sustaining the addition of Rs. 3,17,600/- on account of cash deposit in the bank account. Facts, in brief, are that in this case assessee had not filed his return of income. The case of the assessee was reopened u/s 147 of....