TaxTMI 
TaxTMI 
2023 (2) TMI 577
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....i for the assessment year 2017-18 u/s.143(3) of the Income Tax Act, 1961 (hereinafter the 'Act') for the assessment year 2017-18 vide order dated 10.12.2019. 2. The only issue in this appeal of assessee is against the revision order passed by PCIT while exercising power u/s.263 of the Act in regard to cash money deposited during the year amounting to Rs.86,00,000/- and an amount of Rs.15,49,408/- utilized towards cash payment for purchase of immovable property. For this issue assessee has raised various grounds which are argumentative in nature and hence, need not be reproduced. 3. Brief facts are that the assessee is an individual assessed to income-tax. She has filed her return of income for the relevant assessment year 2017-18 on 08.12....
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....e explanation of the assessee that she has received cash of Rs.1,39,50,000/- during the financial year 2012-13 on account of sale of agricultural land, which was kept as cash at her house for 4 years and deposited this Rs.86,00,000/- in the bank account and utilized Rs.15,49,408/- towards purchase of immovable property from this very cash during the financial year 2016-17 relevant to assessment year 2017-18. The PCIT directed the AO to examine this issue because during original assessment proceedings in regard to this deposit of cash of Rs.80,00,000/- and utilization of cash of Rs.15,49,408/- towards purchase of immovable property was never examined in the scrutiny assessment. The PCIT finally held in para 8 & 9 as under:- 8. In additions....
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.... at the first time the AO has examined this issue and noted the same in para 7 as under:- "7. The assessee has claimed the sources for the Cash Deposit is on account of Sale of immovable property being two agricultural lands during F.Y.2012-13 relevant to the Asst.Year 2013-14. The assessee has received total consideration of Rs.1,39,55,000/- by way of Cash towards the sale of immovable property. The assessee has stated that the sale consideration were invested in purchase of a residential property in June, 2016 for a sum of Rs.1,07,00,000/- and the balance of Rs.30,00,000/- was deposited in Bank during demonetization period. " Further, he stated that the assessee has explained the cash deposit of Rs.86,00,000/- in savings bank account m....