TaxTMI 
TaxTMI 
2024 (2) TMI 832
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....s "the Act"), dated 27.12.2019. 2. The grounds of appeal raised by the assessee are as follows: "1. On the facts and in the circumstances of the case, the Ld. AO has grossly erred in making addition of Rs. 7,00,000/- by invoking the provisions laid under section 69 of the Income Tax Act and considering the explanation given with respect to cash deposition in bank account during demonetization period, arbitrarily as bogus and held as accommodation entry without appreciating the submissions made during the course of assessment proceedings. Thus, the addition of Rs. 7,00,000/- deserves to be deleted; 1.1 That, the Ld. AO has further erred in holding that the submission of cash book of previous 3 years from the year under consideration by ....
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..... 4,15,420/- after claiming deduction under Chapter-VI of Rs. 15,54,389/-. The return of income was processed u/s 143(1) of the Income-Tax Act, 1961 on 08.09.2017. Later on, the assessee`s case was selected for Limited Scrutiny through CASS. Accordingly, a notice u/s 143(2) of the Income-Tax Act, 1961 was issued on 21.09.2018 by ITBA system and duly served upon the assessee. Thereafter, notice u/s 142(1) of the Income-Tax Act, 1961 dated 8.02.2019, along with detailed questionnaire calling for various details was issued in electronic mode and served upon the assessee. In response to the aforesaid statutory notices, Authorized Representative (AR) of the assessee submitted the required details by E-Mode from time to time during the course of ....
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....hat he was engaged in carrying business of manufacturing of corrugated Boxes & Printing with the partnership firm in the name and Style of M/s.Akash Offset Print. During the year under consideration, the assessee filed his return of income on 06.10.2017 declaring total income of Rs. 4,15,420/- after claiming deduction under chapter- VIA of the Act. During the year under consideration the assessee has deposited Rs. 1,10,000/- in saving bank account which consists of Rs. 7,00,000/- in Central bank of India and Rs. 10,000/- was deposited in HDFC Bank. The brief summary of cash deposited along-with bank details is attached herewith. In respect of cash deposit made during the demonetization period, it is submitted that the assessee has made ....
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....nt consist of notes which were still valid and acceptable in old note currency. Therefore, it is clear that the cash deposit made during demonetization period is but of balance available on hand." 6. However, the Assessing Officer rejected the contention of the assessee and observed that in absence of any satisfactory explanation with respect to nature and source of cash deposit made during the demonetization period to the extent of Rs. 7,00,000/- remains unexplained and constitutes income of the assessee for the year under consideration, the same was treated/assessed as unexplained money u/s. 69A of the Act. 7. Aggrieved by the order of Assessing Officer, the assessee carried the matter in appeal before the ld. CIT(A), who has confirmed ....
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....ase including the findings of the ld. CIT(A) and other material brought on record. I note that during the assessment state, the assessee submitted the following documents and evidences, viz: (1) Response to notice u/s 143(2) of the I.T. Act, 1961 along with submission and attachment dated 27.09.2019 (vide Pb.3-12), (2) Response to notice u/s 142(1) of the I.T. Act, 1961 along with submissions and attachments dated 27.09.2019 and explained the source of cash deposit (vide Pb.13 - 38), (3) Response to notice u/s 142(1) of the I.T. Act, 1961 along with submissions and attachments dated 05.12.2019 and explained the source of cash deposit (vide Pb.39 - 45). (4) Cash Book, Bank book and Bank statement and balance in the cash book was coming since....
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....sessee has received remuneration to the tune of Rs. 10,70,000/- and profit to the tune of Rs. 12,73,620/-. The assessee has submitted the cash deposited during the demonetization and the summary thereof which is placed at paper book page nos.18 to 19 and hence it is quite clear from the cash book, cash flow statement and cash withdrawal from the bank, that assessee has explained the source of cash deposit in bank account in a satisfactorily manner. Hence, I am not inclined to accept the contention of the Assessing Officer in any manner and hence the addition so made is deleted. Hence this ground of the assessee is allowed. 12. Thus, I find that ld Counsel for the assessee has practically submitted all possible evidences in support his clai....