2022 (12) TMI 842

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....ment proceedings u/s 143(3) at an amount of Rs 17,78,840/- is being challenged on facts & law. 2. Because the action is being challenged on facts & law for making addition of Rs. 7,15,000/- by treating cash deposit in bank accounts as income from undisclosed sources u/s 68 whereas per assessee, the said cash deposits in bank accounts are fully explainable and deposited out of cash withdrawals from bank account. Alternatively, quantum of addition is challenged. 3. Because the action is being challenged on facts & law for making addition of Rs. 7,15,000/- by treating cash deposit in bank accounts as income from undisclosed sources u/s 68 whereas per assessee addition has been made on surmises and conjectures without there be....

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....njectures and surmises and the addition has been made purely on ad hoc basis without being supported by any credible evidence. On the contrary, the assessee had given supporting evidence relating to the cash deposited by the assessee. 5. The learned DR opposed the submissions and supported the orders of the authorities below. 6. I have heard rival contentions and perused the material available on record. The learned CIT(Appeals) has decided the issue by observing as under: "9. Ground nos. 1 to 4: The Appellant has e-filed his Return of Income u/s 139(1) of the Income Tax Act, 19(51 on 05.08.2017 declaring total income of Rs. 10,63,840/- which was processed u/s 143(1) of the IT Act 1961. Subsequently the case was selected for ....