TaxTMI 
TaxTMI 
2024 (11) TMI 81
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....res no adjudication. 3. Ground Nos. 2 & 3 raised by the assessee in challenging the action of the ld. CIT(A) in confirming the addition made under section 69A of the Income Tax Act, 1961 ["Act" in short]. 4. We note that the assessee is an individual and no return of income filed. According to the Assessing Officer, the assessee made substantial cash deposit in her bank accounts during demonetization period. The Assessing Officer formulated the said details in tabular form, which is in page 2 of the assessment order. The Assessing Officer observed that the assessee deposited Rs..95,31,000/- during demonetization period. A letter dated 29.07.2019 was issued to the assessee requesting to furnish the details of her income, copies of bank....
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....' family/friends' accounts based on their instructions. The assessee derived marginal commission for facilitating the said transactions. He submits that the assessee acting as a distributor earned an amount of Rs..1,27,187/- in the year under consideration and produced 26AS statement. He explained how the commission income arises with an example, which reads as under: Let's say Mr. X wants to send an amount of Rs. 1,000 to his family. He will approach the retailer and hand over cash Rs. 1,005 to the retailer. The retailer will hand over Rs. 1,005 to the Appellant. The assessee will deposit this money in her savings bank account. Once the amount is credited in the assessee's savings bank account, the assessee will transfer the a....
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....to hand over the cash to the retailer/the assessee and provide the details of the person to whom the amount is to be transferred. 7. The ld. AR argued that the total income of the assessee, inclusive of commission income, did not exceed the basic exemption limit of Rs. 2,50,000/-. Consequently, there was no obligatory requirement for the assessee to file a return of income under section 139 of the Act for the AY 2017-18. Additionally, due to her minimal turnover (commission income), there was no compulsion to maintain formal books of account as per section 44AA of the Act. Consequently, the assessee did not maintain books of accounts as prescribed under section 44AA of the Act. 8. It was also submitted that in 2019, the assessee faced....
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....ere made which is clear from page 9 & 10 of the impugned order, which clearly shows that there was no assistance from the assessee in furnishing any documents to prove the sources of cash deposits in her bank accounts. The ld. CIT(A) confirmed the order of the Assessing Officer only on the impression why the third party has to gfive cash to the assessee for transfer of money when all the citizens can open a bank account in their name and many rural branches are opened with a view to give banking access to all the citizens of this country. It is clear from the observations that the ld. CIT(A) did not believe the submissions of the assessee and doubted the business activities, which are narrated before us by the ld. AR herein above. Further, ....