2025 (1) TMI 168

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....bad, (Hereinafter to referred to as the Ld.CIT (A))is contrary to law. facts and circumstances of the case. 2) The Ld. CIT(A)erred in passing the order without providing a proper opportunity for the appellant to be heard, despite the appellant's request for an adjournment due to the sudden death of the appellant's authorised representative. By denying the appellant the opportunity to present case, the Ld. CIT(A) has violated the principles of natural justice. Therefore, the order passed by the Ld. CIT(A) needs be quashed. 3) The Ld. CIT(A) has grossly erred in law as well as on facts in confirming the addition made under Section 69A of the Income Tax Act, 1961, by the Assessing Officer to the tune of Rs. 10,07,000/....

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....memaker did not have any formal business experience or financial acumen. During the year under consideration on 08/11/2016 when the demonetisation of specified banknotes was announced, assessee deposited the entire cash holdings amounting to Rs. 10, 07, 000/-in her bank account. Subsequently she invested the said amount in fixed deposits in her name. 2.2. During the year under consideration assessee received notice under section 142 (1) to file the return of income. The notice was based on the data gathered during the online verification phase under operation clean money, wherein individuals who deposited substantial cash during the demonetisation were targeted. All subsequent notices were sent to the assessee's tax portal and due to her....

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.... by the assessee out of the same from the accounts held by her with yes Bank, OBC bank, AP Mahesh cooperative bank. He submitted that the said amount was accumulated by the assessee out of her savings and cannot be doubted. 5.2. The Ld.AR placed reliance on bank statements at page 25-35 of the paper book, wherein the assessee has sufficient cash that was withdrawn from time to time in the part, out of which certain amount was kept in her hands and the balance was deposited back. The Ld.AR submitted that in this manner assessee accumulated Rs. 10,07,000/-the court deposited into her bank account during that the demonetisation period. The Ld.AR prayed that the amount deposited cannot be treated as unexplained under section 69 a of the act.....