2023 (12) TMI 279

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....s grossly failed to appreciate that No proper, reasonable & sufficient opportunity of being heard was provided to the appellant in utter disregard to the judgments in the cases of principles of natural justice. 2. That the C.I.T.(A) has grossly failed to appreciate that the assessment was completed on the non-est return and explanation about cash deposit in bank account by the assessee was never sought. 3. That Ld. C.I.T.(A) has grossly erred in not asking for the remand report on the return filed on 20.12.2019 vide E-Filing acknowledge number 275120610201219 before the day of assessment. 4. That the C.I.T. (A) was not legally correct and justified in confirming the addition of Rs. 2,10,000/- in bank deposits u/s ....

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....her basis to make addition for this year except as discussed in the body of the order." 4. Per Contra, the Ld. DR could not controvert that the addition in this case is without any seized material during the search. 5. We note that in this case, the addition made by the AO by observing as under:- "From the Bank Statements received from the Kangra Co-operative Bank Ltd., Kotak Mahindra Bank and Axis Bank for the previous year relevant to this assessment year it transpires that :- The Assessee has deposited a sum of Rs 2,00,000/- with the Kotak Mahindra Bank during the period 01.04.2013 to 31.03.2014. As no source of this deposit has been explained by the assessee, this sum of Rs 2,00,000/- is being added to the declar....