2024 (11) TMI 150

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....rief. The assessee is an Individual and is an aged lady. She is engaged in the business of selling religious items like Sandal wood, Janoi, Diva etc in a Parsi Temple. The Ld A.R submitted that her husband was a priest in that temple and he has since expired. She filed her return of income for the year under consideration declaring a total income of Rs. 1,61,700/-. The AO noticed that the assessee has deposited cash aggregating to Rs. 20,32,000/- in her bank account in November, 2016, i.e., during the period of demonetization. Hence the return of income filed by the assessee was taken up for scrutiny. Before the AO, the assessee offered following explanations with regard to the sources of deposits made into her bank account:- (a) Past savi....

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.... pious activities carried on by them. Accordingly, he submitted that, considering her age and the fact that she is carrying on business on a small scale, the claim of savings of Rs. 7,20,000/- made over a long period should not have been doubted with by the tax authorities. With regard to the claim of inheritance of cash of Rs. 7,80,000/- from her husband's brother's wife, the Ld A.R submitted that the assessee was only surviving person, when her husband's brother's wife named Mrs Mehro Darab Dalal expired and she was 87 years old then. They were staying together and the expired lady was also carrying on business on a small scale. She was in possession of cash of Rs. 7,80,000/- when she expired and the same was also inherited by the assesse....

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.... claim with evidences, since she was not required to maintain books of accounts under the law. It is also possible that the said savings could be from her own business and other own sources and it may include money received from her husband also over the years. Accordingly, considering her age and the business activities carried on by her, we are of the view the claim of past savings of Rs. 7,20,000/- could be accepted. We notice that there is one more reason to accept the explanations of the assessee, i.e., the assessee has voluntarily disclosed a sum of Rs. 5,72,000/- under PMGKY scheme, which fact shows that money, which could not be explained was offered as income. The corollary is that the assessee was sure that her explanations with r....