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2022 (10) TMI 625

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....appeal filed by the assessee is directed against the order of the Commissioner of Income Tax (Appeals), Puducherry, dated 28.06.2019 and pertains to assessment year 2011 - 12. 2. We find that appeal filed by assessee is barred by limitation, for which, necessary petition for condonation of delay explaining the reasons for the delay, has been filed. The learned counsel submitted that assessee coul....

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....f Rs.6,23,500 as unexplained credits. 3. The CIT(A) failed to appreciate that the entire cash deposits were duly explained before the officer in the course of assessment proceedings and having accepted a portion of the deposits, the rejection of the explanation for this amount was only on surmises and conjectures and hence the addition is unjustified. 4. The C!T(A) further failed to apprecia....

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....The assessee has not filed return of income for the AY 2011-12. Therefore, the assessment has been re-opened u/s.147 of the Act, and notice u/s.148 of the Act, was issued. The assessee neither responded nor filed any return in response to the notice u/s.148 of the Act. The case was taken up for scrutiny and during the course of assessment proceedings, the AO called upon the assessee to produce nec....

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.... 2011- 12. In response, the assessee through her Authorized Representative submitted that cash deposits into bank account is out of rental income. The assessee further submitted that she had made two major deposits on two different dates i.e. Rs.4 lakhs on 06.12.2010 & Rs.2.5 lakhs on 04.01.2011 and similar amounts has been withdrawn on 25.11.2010 and on 28.12.2010 from very same bank account. The....