2025 (5) TMI 604

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....l preferred by the assessee emanates from the order of the Ld. CIT(Appeals)/NFAC, Ahmedabad dated 28.01.2025 for the assessment year 2017-18 as per the following grounds of appeal on record: "1. The Order of the ADDL/JCIT(A)-2, Ahmedabad is contrary to law, facts and circumstances of the case. 2. That on the basis of facts and circumstances of case of Appellant, the ld. Assessing Officer, ITO,....

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.... books were neve been rejected by Id. AO and Ld. ADDL/JCIT(A)-2, Ahmedabad has erred for confirming the same. 4. The Ld. AO and ADDL/JCIT(A)-2, Ahmedabad ought to have appreciated it is not the case that deposits in SBN has come out from undisclosed sources or under suspicious circumstances only to change the colour of money. 5. That, Appellant reserves the right to add, amend, alter or withdr....

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....isclosed sources of income. The only contention of the department regarding addition is that such cash deposits were made in SBNs currency during demonetization period. The department has failed to bring out that such cash deposits are unexplained since the fact remains that the department has not disputed the business source income of the assessee. Therefore, in effect addition cannot be made in ....

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.... are not available every time at one single place. These realities have also not been disputed by the department. The Department has not questioned the turnover of the assessee and also has accepted the business module conducted by the assessee. Books of accounts of the assessee has also been accepted by the department. When all these parameters have been fulfilled by the assessee, there cannot be....