2022 (2) TMI 484

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....000/- being cash deposited in the bank account of the appellant for which addition under section 68 of the Act was made by the AO. He ought to have applied peak credit theory based on the facts and circumstances of the case. 3. That the Ld. CIT(Appeals) has erred in law in confirming the addition to the tune of Rs/4,59,000/- without accepting the explanation of the appellant and without finding anything contrary to the various judicial pronouncements relied upon by the appellant. 4. That the Ld. CIT(Appeals) has erred in law in confirming the addition only on surmises and conjectures contrary to the evidence on record. 5. That the Ld. CIT(Appeals) has erred in law by granting partial relief against the additions made by AO as appellan....

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....he cash flow statement. However, the Assessing Officer after considering the reply, made addition of Rs. 7,59,000/-. 4. Aggrieved against this, the assessee preferred appeal before Ld. CIT(A), who after considering the submissions, partly allowed the appeal and reduced the addition by Rs. 3 Lakhs. 5. Aggrieved against this, the assessee preferred appeal before this Tribunal. 6. Ld. Sr. DR supported the order of Ld. CIT(A) and submitted that Ld. CIT(A) has justifiably reduced the addition by considering the submissions of the assessee. 7. I have heard the Ld. Sr. DR and perused the material available on record and gone through the orders of the authorities below. Before Ld. CIT(A), it was stated that maximum peak balance credit in the ba....