2024 (12) TMI 1374

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....ent was framed by the Assistant Commissioner of Income Tax, Circle-1, Nagercoil for the assessment year 2017-18 u/s.143(3) of the Income Tax Act, 1961 (hereinafter the 'Act'), vide order dated 30.12.2019. 2. Brief facts of the case are that the assessee is a Trust running a school in Thiruvattur panchayat, catering to students in that remote village and only source of income is out of the fees collected from students. The assessee trust had filed return for the assessment year 2017-18 admitting a total income of Rs. 18,15,130/-. The case was selected for scrutiny by CASS for a reason that high value receipt of cash shown from third parties in response data. In response to Notice under section 142 (1) of the Act dated 07.12.2019 calling for....

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....ng the cash deposits made during the demonetization period maintained by Mulagumoodu Branch solely on the ground that the appellant could not bifurcate the deposits made in SBNs and non SBNs in the said branch. The appellant had obtained the said certificate from the bank, Mulagumoodu Branch, showing the breakup of the deposits in SBNs and non SBNs. The above fact of deposit of SBNs only to the extent of Rs. 6,66,500/- at Mulagumoodu Branch was also confirmed by the Assessing Officer in the remand report dated 07.03.2024. Further, the assessee had also established during the remand proceedings that the closing cash balance as on 08.11.2016 was at Rs. 17,82,947/-. In fact, the total deposits made in SBNs in both the branches was only to the ....