2022 (2) TMI 427

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....d against the order passed by the CIT(A) on 14-08-2020 in relation to the assessment year 2011-12. 2. The only issue raised in this appeal is against the confirmation of addition of Rs. 13,05,000/- in respect of cash deposited in the bank. 3. Tersely, the facts of the case are that the assessee has been a salaried employee at the material time and now a retired person. A sum of Rs. 15.05 lak....

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....wo persons before the ld. first appellate authority, which clearly transpired that the loan was taken by the assessee for further foreign studies of his daughter. This contention was rejected by the ld. CIT(A) on the ground that the assessee did not submit any documentary evidence of having taken loan for his daughter's further studies. Once the advancement of loan was confirmed by the lenders....

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.... of agricultural operations and cultivation done. Again, the fact that the assessee was regularly into agricultural operations has not been denied. I am unable to comprehend the point of view canvassed by the ld. first appellate authority in the hue of the fact that the assessee did furnish sale receipt of agricultural produce which has not been found to be non-genuine or bogus and no contrary mat....

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.... circumstances of each transaction are required to be considered in entirety. Here is a case in which a salaried person pooled his lifelong endeavour for the further studies of his daughter. In such a panorama, a holistic approach needs to be adopted. When I consider the facts of the instant case as a whole, there remains no doubt whatsoever that the assessee arranged the money from his known sour....