TaxTMI 
TaxTMI 
2022 (6) TMI 892
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....Tax (Appeals), Puducherry dated 25.02.2019 in I.T.A.No.96/CIT(A)-PDY/2017-18 for the above mentioned Assessment Year is contrary to law, facts, and in the circumstances of the case. 2. The CIT (Appeals) erred in confirming the re-assessment u/s.143(3) read with section 147 of the Act without assigning proper reasons and justification and ought to have appreciated that the order of re-assessment under consideration was passed out of time, invalid, passed without jurisdiction and not sustainable both on facts and in law. 3. The CIT (Appeals) erred in sustaining the addition of Rs.54,25,330/- being the cash deposits after rejecting the explanation offered for the source in the computation of taxable total income without assigning proper re....
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....r sources'. The assessment has been completed u/s.143(3) r.w.s.147 of the Act, dated 28.12.2017 and determined total income at Rs.74,34,540/- by making addition of Rs.54,25,330/- towards excess amount deposited into bank account under the head 'income from other sources'. 4. Being aggrieved by the assessment order, the assessee preferred an appeal before the Ld.CIT(A). Before the Ld.CIT(A), the assessee challenged re-opening of assessment and also contested additions made by the AO towards cash deposits to bank account under the head 'income from other sources'. The Ld.CIT(A) for the reasons stated in his appellate order dated 25.02.2019 rejected the contentions of the assessee and sustained additions made by the AO towards source of cash ....
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....e have heard both the parties, perused the materials available on record and gone through orders of the authorities below. The facts borne out from the record clearly indicate that the present assessment proceedings have been re-opened second time. The assessee has furnished copies of reasons recorded for first re-opening of assessment and second re-opening of assessment. We have perused reasons recorded by the AO for re-opening of assessment on both occasions and we find that the assessment has been re-opened for the first time to verify cash deposits found in bank account. The assessee had offered an explanation and explained source for cash deposits into bank a/c, as per which, the assessee had received cash consideration for sale of pro....