2025 (6) TMI 976

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....DIP KUMAR CHOUBEY, JM: This is the appeal preferred by the revenue against the order of Commissioner of Income Tax (Appeal)-NFAC, Delhi (hereinafter referred to as the Ld. CIT(A)] dated 05.10.2023 for AY 2018-19. 2. Brief facts of the case are that the assessee Sri Debasish Das, being an individual, did not file his return of income for the impugned AY 2018-19 within the due dates stipulated....

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....he impugned assessment order u/s. 144 r.w.s 147 r.w.s 144B, dated 28.02.2023, determining the total income of the assessee at Rs. 1,47,91,020/-. While doing so, the AO made an addition of Rs. 1,47,91,020/- towards unexplained income. 3. Aggrieved by the said order, the assessee preferred an appeal before the Ld. CIT(A) wherein the appeal of the assessee has been allowed. Being aggrieved and ....

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....ssion of the counsel of revenue, we have perused the order passed by the Ld. CIT(A). On perusal of the facts of the case of the assessee, it appears to us that the assessee deals in CSP and having very marginal income i.e. below the taxable amount so the assessee did not file return of income. It further appears to us during the course of appellate proceedings, the assessee filed submission in the....

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....ative part has held thus: "The main issue in the appeal is pertaining to the credit and debit entries of small amounts in the bank account statement bearing no. 34237976729 in State Bank of India. As verified from the bank account statement, it is noticed that there are 49 pages of transactions and each page contain approximately 70 transactions of both debit and credit with the varying a....