2024 (11) TMI 1311

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....R PER MANU KUMAR GIRI (JUDICIAL MEMBER) This appeal by the assessee is directed against the order No.ITBA/NFAC/S/250/2023-2024/1062618166 (1) dated 14.03.2024 of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi. The assessment was framed by the Income Tax Officer, Ward 1(2), Salem for the assessment year 2017-18 passed u/s.144 of the Income Tax Act, 1961 (h....

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....sessee to file the returns belatedly he could not file his return of income belatedly. As regards, the source of cash deposited in the bank account during demonetization period, the assessee inter-alia had submitted as under: - Sl.No Nature of Sources Amount 1 Op. Cash Balance (1.04.2016) 1,36,538 2 Rentals received 2,82,000 3 Sale of gold jewellery 6,85,984 4 Cash Withdrawals from T....

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....e the assessee did not render any explanation for the above transactions of Rs. 2,09,35,362/- i.e., the cash and other transactions related to the period other than demonetization period, the ld. Assessing Officer assessed the same on presumptive basis at the rate of 8% and estimated income of Rs. 16,74,829/-. However, the entire cash deposit during demonetization period was added as unexplained i....

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....ted 12.09.2019 requested the assessee to explain the cash and other banking transactions during the period from 01.04.2016 to 31.03.2017 which assessee failed to do so. In the absence of any credible supporting documentary evidences forthcoming from the assessee, the ld. CIT(A) estimated the business income @5% of the total cash deposit of Rs. 2,09,35,362/- as against estimation of 8% as made by L....