2025 (5) TMI 28

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....of Rs. 5,19,239/- confirmed by the CIT(A) on account of unexplained source of capital and rejection of books of accounts and consequent estimation of profits @ 8% of the total turnover. The ld. Counsel submits that the assessee had explained before the Assessing Officer (AO) and the CIT(A), that the assessee had introduced new capital of Rs. 27,05,000/- in the business from sale of house Rs. 24,00,000/- and gifts received from relatives Rs. 3,05,000/-. The CIT(A) partly accepted submissions of the assessee i.e. to the extent of funds received from sale of immovable property and confirmed the remaining amount. 2.1. The ld. Counsel for the assessee further contended that the AO and the CIT(A) have erred in estimating profits from business ....

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.... 5. As per TEP, the assessee introduced new capital to the extent of Rs. 29,19,239/- from undisclosed sources. As per the assessee, the assessee introduced fresh capital to the extent of Rs. 27,05,000/- in her business of manufacturing and trading of PP/HDPE woven sacks. During assessment proceedings, the assessee was asked to explain source of funds for introduction of fresh capital in her proprietorship business. The assessee explained that fresh capital was sourced from sale of residential house in village within laal dora Rs. 24,00,000/- and gifts received from relatives Rs. 3,05,000/-. The AO rejected submissions of the assessee as they were unsubstantiated and made addition of the entire amount of Rs. 29,19,239/-. 5.1. In First ....