2024 (2) TMI 886

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....ed 10.05.2023 against the order of assessment passed u/s 143(3) of the Income-tax Act, 1961 (hereinafter referred to as "the Act") dated 11.04.2021 by the Assessing Officer, ACIT, Central Circle-4, Delhi (hereinafter referred to as "ld. AO"). 2. Though the assessee has raised several grounds of appeal, the only effective issue to be decided in this appeal is as to whether the ld CIT(A) was justified in treating the cash seized of Rs. 13 lakhs as unexplained money u/s 69A read with Section 115BBE of the Act in the facts and circumstances of the instant case. 3. We have heard the rival submissions and perused the material available on record. A search and seizure action u/s 132 of the Act was carried out in "Ritika Pvt. Ltd" (RPL) group....

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....ng the course of assessment proceedings as to how the cash had actually travelled from Kolkata to Gurgaon and who carried the same. 4. We find that the assessee had duly furnished the cash reconciliation statement before the lower authorities as under:- "Reconciliation statement of cash balance as per books and as found by Investigation team during search on 29.05.2018 from 260, Udvog Vihar, Phase 1, Gurgaon" Particulars Amount (in Rs.) Balance of cash on 29.05.2018 in the books of the assessee:   Balance of cash on 29.05.2018 as per cash book at Gurgaon branch (domestic unit) 2,80,788 Balance of cash on 29.05.2018 as per cash book at Gurgaon branch (Export unit) 2,08,935 Balance of cash on 29.05.....