2023 (1) TMI 567

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..... AR appeared for the assessee and Shri M.K. Gautam, Ld. CIT DR appeared for the revenue. 3. At the time of hearing, Ld. AR did not wish to press the cross objection and has endorsed in the file to this effect. Consequently, the cross objection filed by the assessee stands dismissed. 4. In respect of Revenue's appeal, it was submitted by Ld. CIT DR that there was search on the premises of the assessee on 28.5.2008. Notice u/s. 153A came to be issued on 5.3.2010. No return of income was filed and there was no compliance. Consequently, the assessment came to be completed u/s. 144 of the Act, wherein, the AO had brought to tax the fixed deposits found during the course of search to an extent of Rs. 6.5 crores. It was the submission that ....

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.... the fixed deposits. It was the submission that the assessee did not explain the source for the fixed deposits and in any case, there was no explanation in respect of the fixed deposits in respect of the family members in respect of Rs. 1.5 crores. It was the further submission that the order of the Ld. CIT(A) is liable to be reversed to the extent he has granted relief to the assessee. 5. In reply, Ld. AR vehemently supported the order of the Ld. CIT(A). It was the submission that the assessee having been received the amount of Rs. 9,16,66,750/- during the relevant assessment year and same having been offered to tax and the taxes having been paid, there was adequate source for the fixed deposit of Rs. 6.5 crores in its entirety. It was th....