2022 (5) TMI 333

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.... of alleged unexplained cash deposit in bank account of assessee. 2. On the facts and in the circumstances of the case as well as subject on the law, Id. CIT(A) has erred in giving direction to Assessing Officer to reopen the case of assessee for A.Y. 2013-14 by invoking the provisions of section 150(1) of the Act. 3. It is therefore prayed that addition made by assessing officer and confirmed by CIT(A) may please be deleted and direction given by CIT(A) may please be quashed. 4. Appellant craves leave to add, alter or delete any ground(s) either before or in the course of hearing of the appeal." 2. Learned AR submitted that the ld. CIT(A) has erred in confirming the action of the Assessing Officer in making ad....

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....xt financial year. Therefore, entire addition may kindly be deleted. 4. Replying to the above, ld. Sr. DR supported the action of the Assessing Officer and placed reliance on the assessment order. He also drew our attention to page 8 of first appellate order and submitted that the Assessing Officer has made addition u/s. 68 of the Act on account of cash deposits in the bank account and he was very clear in his approach that although total cash deposit was Rs.79,04,282/-, but instead of making addition of whole amount, the Assessing Officer proceeded to calculate the peak amount of the deposit by allowing benefit of withdrawals made in cash. 5. On careful consideration of the rival submissions, I am of the considered view that the ld. ....