2024 (5) TMI 821

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.... PER LALIET KUMAR, J.M. The appeal of the assessee for A.Y. 2017-18 arises from the order of Commissioner of Income Tax (Appeals), Addl/JCIT (A), Udaipur dt. 06.02.2024 invoking proceedings under section 144 of the Income Tax Act, 1961 (in short, "the Act"). 2. The grounds raised by the assessee read as under : "1. On the facts and in the circumstances of the case, the order of the....

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....essment or appellate proceedings is incorrect." 3. The brief facts of the case are that as per the information available in AIMS module of ITBA, cash deposits of Rs. 11,08,310/- were made by the assessee in the bank accounts during the demonetization period. On the basis of such information, a notice u/s. 142(1) dated 12.03.2018 was issued and was duly served. Vide the notice u/s. 142(1), the a....

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....oks standing in the name of self and family members. Moreover, the assessee submitted copies of sale bills of paddy, which are self made and are not convincing evidences. In view of the failure on the part of the assessee in substantiating the claims made with supporting evidences and thereby failed to explain the sources of cash deposits appearing in the bank accounts. Hence, all the cash deposit....

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....cer The Ld. A.R. further submitted that the source of the cash deposits was well-documented and readily available on record. The ld. AR pleaded that considering the above legitimate facts and circumstances, the addition of unexplained income was unwarranted and should be deleted. 6. Per contra, the ld. DR had relied upon the orders of lower authorities. 7. I have heard the rival contentions ....