2023 (4) TMI 992

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.... with the reasons given in the petition and accordingly condone the delay. The appeals are, therefore, admitted for disposal of merits. ITA No.310/PUN/2023 - A.Y. 2013-14 : 3. The assessee is aggrieved by the confirmation of addition of Rs.1,38,192/- made by the Assessing Officer by not granting deduction u/s.80P(2)(a)(i) of the Income-tax Act, 1961 (hereinafter also called 'the Act') on the interest income. 4. Briefly stated, the facts of the case are that the assessee is a credit cooperative society, which did not file its return for the year under consideration. The AO initiated re-assessment proceedings by means of notice u/s.148. In such notice, it was alleged that the assessee deposited cash in saving bank account amounting t....

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....4. On verification of the ITD/ITBA System, it is found that the assessee has not filed the ITR within due time. The sources of these cash deposit of Rs.1,92,85,640/- is needed to be verified. Similarly, the due taxes arising from these transactions are also remained to be taxed. Therefore, the assessee has failed to disclose the income on account of cash deposits and has escaped assessment". 6. Thus, it is evident that the AO initiated re-assessment proceedings on the ground that the cash deposited in savings bank account and with banking company was not properly verifiable. He, however, eventually got satisfied with the assessee's explanation on the above score. Thereafter, he chose to make an addition towards interest income earned by ....

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....cash deposited in the bank. However, in the eventual assessments made u/s.147, the AO did not make any addition on that score but reduced the claim of deduction u/s.80P by denying it on the interest income. Following the view taken hereinabove, I order to delete the addition made for both the years. ITA No.333/PUN/2023 - A.Y. 2017-18 : 9. The assessee in appeal for this year is aggrieved by the confirmation of addition of Rs.22,89,000/- u/s.69A towards cash deposited in the bank account and a further addition amounting to Rs.23,13,273/- towards estimation of income on amount deposited in the bank account. 10. Shorn of unnecessary facts, it is seen that the AO completed the assessment u/s.144 computing total income at Rs.46,02,270/-....