2022 (12) TMI 220

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....e for the assessment year 2011-12 on 14.09.2011 admitting total income of Rs..8,94,648/-. Subsequently, the case was selected for scrutiny through CASS and notice under section 143(2) of the Income Tax Act, 1961 was issued to the assessee on 31.07.2012. After considering the details furnished by the assessee against statutory notices and by following due procedure, the Assessing Officer has completed the assessment under section 143(3) of the Act dated 12.03.2014 assessing total income of the assessee at Rs..67,29,846/- by making addition towards unexplained cash deposit of Rs..57,89,000/- and disallowance of depreciation at Rs..46,198/-. On appeal, after considering the submissions of the assessee and the remand report of the Assessing Off....

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....assessee are documents related to the source for cash deposits such as the ledger accounts jewel loan statement from Kumbakonam Mutual Fund Benefit Fund Ltd., etc. On perusal of the additional evidences, the following observations are made: Date Cash deposits Source 22.04.2010 15000 No reasonable evidence is submitted. Moreover, the pattern of rent amount and period is not in line. Therefore, the entire amount of Rs.1,01,000/- is to be added back as unexplained cash credit. 09.02.2011 45000 05.03.2011 35000 22.03.2011 6000 16.07.2010 1900000 Jewel loan received on 15.07.2010 and 16.07.2010 to the tune of Rs..15,60,000/-. Though there is matching between the dates of loan amount received and cash ....

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....d on 10.02.2011 and on 17.02.2011 on repledging the jewels discussed in previous para to the tune of Rs..11,60,000/-. Here, there is no reasonable matching between the dates of loan amount received and cash deposited. Since, the source for jewels is already considered (unexplained and added) in the preceding para, telescoping is given. Therefore, the source is explained. 01.03.2011 350000 03.03.2011 500000 06.07.2010 500000 Sale proceeds from the customer Shri Venkatraman. It is considered as source as this amount is reflected in the books of company, customer as well in the assessee account. 26.11.2011 790000 Though there was cash withdrawn on 24.11.2010, 26.11.2010 to the tune of Rs..9,00,000/- and Rs..4,00,0....