2023 (6) TMI 179

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....sessment Year (A.Y.) 2017-18. 2. Brief facts of the case are that the assessee filed his return of income on 27.10.2017 declaring a net taxable income of Rs.9,78,280/-. The return was processed 143(1) of the Act and the case was selected for limited scrutiny under CASS for the reason "Cash deposit during the year". Notices u/s 143(2) and 142(1) were issued calling for information in respect of the nature and sources of cash deposits made by the assessee along with a copy of the bank account maintained by him. As there was no response, show cause notice was issued on 21.11.2019. In response to which, the assesee filed his reply along with bank account statements maintained with State Bank of India and Indian Bank. Since the assessee has not....

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....the Act. The Ld.AR submitted that the assessee is a proprietor of Alameer Sai Wines, dealing with IMFL retail with license approved from Andhra Pradesh State Excise and Prohibition Department, as per the license condition, the assessee has to purchase IMFL from Andhra Pradesh Beverage Corporation Ltd. (APBCL) for onward retail sale. The assessee is a regular filer of income tax returns. The Ld.AR further submitted that Sri B.Suryanaraya, Prop.Karthikeya Wines, a close associate of the assessee requested the assessee to transfer on behalf of him to APBCL for purchase of IMFL, for which cash of Rs.36,50,000/- was received and deposited into the bank account and the balance amount of Rs.7,33,000/- was transferred from his bank account to asses....

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....the assessee by providing any confirmation letter from Shri B.Suryanarayana before the revenue authorities or before us. Further, from the order of the Ld.CIT(A), I observe that the assessee has not accounted both the transactions i.e. payment to APBCL or amount received from Shri B.Suryanarayana. As per the provisions of sec.69A of the Act, "where in any financial year the assessee is found to be the owner of any money, bullion, jewellery or other valuable article and such money, bullion, jewellery or valuable article is not recorded in the books of account, if any, maintained by him, for any source of income, and the assessee offers no explanation about the nature and sources of acquisition of the money, bullion, jewellery or other valuab....