TaxTMI 
TaxTMI 
2025 (6) TMI 210
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....ent from the bare perusal of the orders of learned PCIT, the impugned orders passed u/s. 263 of the Act has sought revision of the orders passed u/s. 147 of the Act in both the years in the case of the assessee on an identical issue. The order of the ld. PCIT reveals that he found the assessment order passed u/s. 147 by the Assessing Officer to have been erroneously passed by blindly accepting of the contentions made by the assessee explaining the source of cash deposits in her bank account to the tune of Rs. 1.16 crores in A.Y. 2015-16 and Rs. 2.81 crores in A.Y. 2014-15 as arising from her business in dealing in sports goods without a shred of evidence being filed by the assessee in support of the same and the Assessing Officer conducting....
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....filed. No books of account were maintained by the assessee and even principal place of business, godown, trading expenses, opening and closing stocks, which are all basic ingredients of any business were missing in the case of the assessee and the AO made no enquiry with respect to the same. Learned PCIT further notes that against cash deposits of 3.27 crores in her bank account in A.Y. 2014-15, there were huge withdrawals of Rs. 3.31 crores. The assessee is running voluminous business, but there was no expenses incurred on hiring of professionals and employees etc. which again was not looked into or enquired by the Assessing Officer. Learned PCIT notes that the assessee had submitted to have made all purchases from unregistered manufacture....
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....ply dated 07.06.2019 that the banking transactions actually relates to the partnership firm M/s. Misha Exports in which her husband namely Sh. Deepak Mahajan is a partner. The assessee also furnished some wild reasons for such transactions which could not be held justifiable and supported by any documentary evidences. But during the assessment proceedings before the JAO, the assessee submitted vide her reply dated 26.03.2022 that she is in the business of trading of sports goods having its principal place of business at Meerut Further, she also submitted that all the transactions in the bank account are related to sales proceeds of goods of her own business. The assessee presented two different stories at two different occasions which remai....
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....ccount, filling of ITR etc. are totally unacceptable. iv) That throughout the proceedings, the assessee tried to present fabricated story regarding deposition of cash out of sale proceeds of her purported business, which had been wrongly accepted by the Assessing Officers without applying his investigative and judicious mind while assessing the income of the assessee on presumptive basis. v) That out of total credit of Rs. 4.17 crore, there is cash deposits to the tune of Rs. 3.27 crore from different locations across the country. Further, there is also substantial cash withdrawal to the tune of Rs. 3.31 crore. For running such a voluminous business, the assessee must had also incurred proportionate expenses. on hiring of ....
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....ank account is on much higher side. No effort has been made by the AO to arrive at true and accurate volume of transaction. No enquiry was made by the AO from concerned Bank and related parties(sale/purchase)." 3. Before us, learned counsel for the assessee was unable to controvert any of the factual findings of the ld. PCIT with regard to there being nothing on record substantiating assessee's claim of running a sports equipments trading business. The assessee was also unable to controvert the findings of the ld. PCIT of there being several anomalies in the manner of conducting business noted by the ld. PCIT, which created doubt about the existence of any sports business carried out by the assessee at all. During the course of hearing, ....