2024 (6) TMI 1339

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....660 towards cash deposits during demonetisation period. 2. The brief facts of the case are that the assessee is having PAN BNNPM 0004K and information was received regarding substantial amount of cash deposits during the demonetisation period and assessee did not file return for AY 2017-18 within the due date prescribed u/s 139(1) of the act. Accordingly notice dated 12.03.2018   u/s. 142(1) was issued to the assessee calling for return on or before 31.03.2018 but did not respond. The assessee also did not respond to the notice dated 06.03.2019 and the AO independently called information from Karnataka Bank and it was noticed that the assessee as maintained 3 bank accounts no. 9257002100511901, 9257002100498801 and 925255001010....

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....re CIT(A) explaining the reason for cash deposits (placed at pg. 20 and onwards) and submitted that the CIT(Appeals) has passed the order on 16.10.2023 without considering the submissions of assessee and the evidence (placed at page 1 to 35 of PB). Accordingly, he requested that the order passed by both the authorities are without taking notice of the submissions made by the assessee and hence the addition deserves to be deleted. 5. The ld. DR relied on the orders of lower authorities. 6. Considering the rival submissions, we note that the assessee is an agriculturist and did not file return of income as he had no taxable income.   The explanation of the assessee regarding substantial amount of cash deposits made in the bank....

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....ariation be found between these statistical analyses. Therefore, it is very important to note that whether the case of the assessee falls into statistical analysis, which suggests that there is a booking of sales, which is non- existent and thereby unaccounted money of the assessee in old currency notes (SBN) have been pumped into as unaccounted money. 8.1 The instruction dated 21/02/2017 that the assessing officer basic relevant information e.g. monthly sales summary, relevant stock register entries and bank statement to identify cases with preliminary suspicion of back dating of cash and is or fictitious sales. The instruction is also suggested some indicators for suspicion of back dating of cash sales or fictitious sales where there is a....