2024 (10) TMI 358

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....is common order, for the sake of convenience. 2. The assessee is an individual. The Revenue received information that the assessee has deposited cash of around Rs. 30.00 lakhs in a joint bank accounts along with his sons in DCB Bank Ltd., Mira Road Branch. Hence the AO reopened the assessments of AYs. 2011-12, 2015-16 and 2016-17 by issuing notices u/s. 148 of the Income Tax Act, 1961 ("the Act"). In response to the notices, the assessee filed her return of income for AY. 2011-12 declaring a total income of Rs. 1,55,480/-. For AYs. 2015-16 and 2016-17, the assessee had earlier filed returns of income declaring a total income of Rs. 2,85,000/- and Rs. 2,90,000/- respectively. The assessee requested the AO to treat the said returns of inco....

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....ly expressed the view that the cash deposits made into the bank account have not been reduced from the Capital Account and hence the same is not reliable. It is seen that the Ld.CIT(A) has confused himself by considering the Capital Account copy as "Cash Flow Statement". Cash outflow by way of bank deposits is reduced is shown as reduction in the Cash Flow Statement and not in the Capital Account. Accordingly, he rejected the explanations furnished by the assessee and dismissed the appeals filed for all the three years. Hence, the assessee has filed appeals challenging the order passed by the Ld.CIT(A) in all the three years. 5. We heard the parties and perused the record. We shall first take up the appeal filed for AY. 2011-12. In this ....

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....We notice that the assessee has filed confirmation letter obtained from the son of the assessee, wherein he has confirmed that he has given gift of Rs. 3.00 lakhs to the assessee. In that letter, he has furnished his PAN number also. We noticed earlier that the bank accounts stand in the joint name of the assessee and her sons. Hence, the contribution made by the son for making cash deposit has been declared as gift. Hence, we do not find any reason to disbelieve the gift transaction. 7. We notice that the assessee has shown opening cash balance of Rs. 15.34 lakhs as on 01-4-2014 out of which it is claimed that a sum of Rs. 10.00 lakhs has been deposited into the bank account. The closing balance as on 31-03-2015 was shown at Rs. 7,67,20....