2025 (6) TMI 215

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....ng in selecting the case under scrutiny which is against the guidelines issued by the CBDT 2. That the notice u/s 143(2) of the Income Tax Act was not issued as per the provisions of law. 3. That the tax authorities were wrong in making following additions to the total income of the appellant:- (a) Rs. 20,00,000/- u/s 68 of the Income Tax Act, (b) Rs. 13,20,000/- u/s 68 of the Income Tax. 4. That the Ld. CIT(A) was wrong in upholding the additions made by the Ld. AO. 5. That the additions were made without providing opportunity to the appellant to submit evidence in support of his case rendering the impugned order untenable in law. 6. That the Ld. AO completed the assessment in ....

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....fter, the case was selected for scrutiny through Computer Assisted Scrutiny Selection (CASS) and a notice issued u/s 143(2) of the Income Tax Act, 1961 ("Act", for short) was duly served upon the assessee. In response to the statutory notices, Ld. Authorized Representative of the assessee attended the assessment proceedings. The Assessing Officer ("AO") while framing the assessment made mainly two additions i.e. addition of Rs. 20,00,000/- u/s 68 of the Act on account of unexplained cash credit made by the assessee and further an addition of Rs. 13,20,000/- u/s 68 of the Act on account of unexplained cash that was deposited in the bank account of the assessee. Thereby, he assessed income at Rs. 36,04,000/- against the returned of income of ....

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.... of Rs. 20,00,000/-, the amount was received on behalf of the company namely M/s. Sewa Developers Pvt Ltd. It is also stated that the resolution was passed authorizing the assessee to collect the amount from petty contractors. It was stated that the sum was collected from various petty contractors and deposited in the bank account of the assessee. Thereafter, this amount was duly transferred to the company. Hence, no tax liability could be fastened on the assessee. The Ld. CIT(A) sustained this addition without verifying the correctness of the explanation of the assessee. If, the assessee is able to demonstrate that the amount so collected was duly transmitted to the bank account of company. In that event, it becomes incumbent upon the tax ....