TaxTMI 
TaxTMI 
2023 (8) TMI 919
X X X X Extracts X X X X
X X X X Extracts X X X X
.... (in respect of addition of Rs. 75,81,000/-) and accordingly denies its liability to pay Tax and Interest charged upon such addition vide Notice of demand. 2. BECAUSE, the authorities below were not justified in making and sustaining addition of Rs. 65,21,000/- which represents sale proceeds of trading receipts undertaken by the appellant. 3. BECAUSE, the learned Assessing Officer has erred in law and on facts in placing reliance upon the so called statement of Gitaram Tyagi without examining said Gitaram Tyagi and without examining his books of accounts and without allowing copies of the alleged statements and also without allowing cross-examination of the party on whose testimony addition has been made. 4. BECAUSE, in any case and i....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ed 27/03/2014 in so far as addition of Rs. 75,81,000/- on account of bank credit entries u/s 69A of the Act, the assessee preferred an appeal before the CIT(A). The Ld. CIT(A) vide order dated 20/10/2015, dismissed the Appeal filed by the assessee. As against the order of the CIT(A) dated 20/10/2015 the assessee preferred the present appeal on the grounds mentioned above. 4. The grounds of Appeal of the Assessee are regarding sustaining the addition of Rs. 65,21,000/- which claim to be sale proceeds of trading receipts undertaken by the Assessee and sustaining addition of Rs. 10,60,000/- claim to be agriculture receipt. The Ld. Counsel for the assessee addressing on the Grounds of Appeal submitted that the assessee is a 'dalali'/ 'agent'. ....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ultural produce. The assessee has also produced confirmation certificate for getting commission in cash from property deals. When the bills produced by the assessee were verified from Agra Alu Trading Company qua there was specific denial of making any payments to the Assessee. The Ld. A.O. made independent enquiry and found that the bill produced by the assessee were fabricated by misusing the letter of M/s Agra Alu Trading Company. The assessee has also not able to file any evidence of carrying out any basic agricultural activities and sale of agriculture produce. Therefore, the claim of treating the income as agriculture by the assessee was not supported by any documentary evidence. Therefore, cash deposits have been rightly treated as u....