2023 (1) TMI 602

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....AL MEMBER:- This appeal is filed by the Assessee as against the order dated 16.03.2018 passed by the Ld. Commissioner of Income Tax (Appeals)-2, Rajkot, as against the assessment order passed under section 143(3) r.w.s. 147 of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') relating to the Assessment Year (A.Y) 2009-10. 2. The brief facts of the case is that the assessee is an in....

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....ed by the assessing officer and therefore the entire cash deposited is treated as unexplained cash deposit and added to the income of the assessee. 3. Aggrieved against the same, the assessee filed an appeal before Ld. Commissioner of Income Tax(Appeals). The Ld. CIT(A) partly allowed the appeal namely the loans received from 13 persons which is below Rs. 20,000/-. However confirmed the additions....

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....s only Rs. 5,00,000/- and disallowed the remaining Rs. 3,87,700/-. The Ld. CIT(A) also failed to consider that there was an opening cash balance of Rs. 7,20,000/- as on 01/04/2008 and assessee filed its Return of Income for A.Y. 2009- 10 showing an income of Rs. 5,46,971/-. The assessee being a Government Servant worked for 18 years, Ld. CIT(A) has estimated the past savings only as Rs. 5,00,000/-....