2022 (1) TMI 1354
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....come tax Appeals ("Ld.CIT(A)") is erroneous and bad in law. 2. That on the facts and circumstances of the case and in law, the Ld. CIT(A) has erred in confirming addition of Rs. 10,00,000/- made by the Learned Assessing Officer ("Ld. AO"). 3. The Ld. CIT(A) has erred in holding that the total cash deposit of Rs. 10,00,000/- out of the cash withdrawals made by the Assessee is unaccounted and unexplained without mentioning any section and thereby making the addition of Rs. 10,00,000/- despite the fact that the source has been explained. 4. The Ld. CIT(A) has erred in relying upon judicial decisions against the assessee which are unconnected and irrelevant and are distinguishable upon facts and in law. 5. That the grounds of appeal....
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....sessee. Now the assessee is in appeal before this Tribunal. 5. Learned Authorized Representative of the assessee vehemently argued that the authorities below are not justified in making the impugned addition. Learned AR further submitted that the assessee proved by documentary evidence in the form of bank statement etc. that the cash was deposited out of withdrawal as made out savings bank account. Learned counsel drew my attention to bank statement and the orders passed by the authorities below. Learned counsel for the assessee submitted that under the facts and circumstances of the case the addition was not called for and deserved to be deleted. 6. Per contra, learned Sr. D.R. Shri Om Prakash vehemently opposed the submissions made on b....
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.... that the learned CIT(Appeals) dismissed the appeal by observing as under: "5.1. I have considered the facts of the grounds. Contention of the AR of the appellant, case laws relied upon by the AR of the appellant. The whole issue is based on the fact that the AO had made an addition of Rs. 10 lac in its bank account which was found to be unaccounted for. Contra, the appellant claims it to be out of the cash withdrawals made by the appellant from the same savings account during the year under consideration. In its support the appellant has also relied on the bank statement and other documents. The AO stressed upon the purpose for which the appellant had withdrawn such a huge amount. However, the appellant continued to stress upon the ma....