2025 (6) TMI 298

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....ssment Year (AY) 2011-12. 2. The Assessee has taken following grounds of appeal:- "01. Notice issued u/s 148 datd.24.03.2018 is bad in law as the same is issued without acquiring valid jurisdiction and accordingly, order passed u/s 143(3) r.w.s 147 dated.30.12.2018 and demand notice issued u/s 156 are bad in law for want of issuance of valid notice u/s 148. 02. Ld. CIT(A) erred in law and on facts in confirming the addition of Rs.59,01,400/- being alleged unexplained cash deposit u/s 69A of the Act without appreciating facts and law of the case properly." 3. The brief facts of the case are that the assessee was stated to be engaged in the business of sale of milk and trading of cattle during the year under consideration. The Assessing....

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....hat since the issuance of this notice was not in accordance with the provisions of the Act, the order dated 30.12.2018 passed u/s 143(3) r.w.s. 147 was not sustainable in the eyes of the law. On merits of the addition made by the Assessing Officer, Ld. AR submitted that the assessee was engaged in the business of being a commission agent for cattle trading, acting as an intermediary between sellers and buyers. Ld. AR submitted that all the amounts deposited into the assessee's bank account during the relevant period were proceeds from cattle sales and the commission earned thereof. He argued that the Assessing Officer had made the assessment without properly considering the nature of his business and the return of income filed. The Ld. AR, ....