TaxTMI 
TaxTMI 
2025 (6) TMI 958
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....Act"] for the Assessment Year [A.Y.] 2017-18, wherein learned CIT(A) has confirmed the addition of Rs. 18,00,200/- made by Assessing Officer u/s. 69A of the Act. 2. None responded for the assessee. Perused records and heard Learned Departmental Representative for the Revenue. 3. Briefly stating, the facts are that the assessee is a non-filer. However, on the basis of information available with the department, it was found out that the assessee deposited Rs. 9,00,100/- in her post office saving bank account No. 3437952676 and Rs. 9,00,100/- in another account No. 3425033097 totaling to Rs. 18,00,200/- during the demonetization period between 09.11.2016 to 30.12.2016. The assessee did neither file return of income u/s. 139 nor respond to th....
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....ssued by the Assessing Officer, the assessee made another detailed submission dated 25.11.2019 with a new story stating that the assessee was engaged in the shoe business since financial year 2008-09. The Assessing Officer being dissatisfied with two contrary responses, assessed total income of the assessee u/s. 144 of the Act as Rs. 18,00,200/- as unexplained investment/credits u/s. 69A of the Act. 4. The assessee could not get favourable order from the first appellate authority, who confirmed the assessment order dated 09.12.2019. 5. The assessee has preferred this appeal on the following grounds : "1- Because upon the facts and in overall circumstances of the case, the order passed by the Ld. CIT(A) dismissing the Appeal filed and co....
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....cause the Appellant has explained in detail the source of her income along with necessary evidences in support, which have not been considered by the CIT(Appeals)." 6. None responded for the assessee. Heard learned DR for the Revenue and perused the records. 7. The small issue for consideration under appeal is as to whether learned CIT(Appeals) has erred in confirming the addition of Rs. 18,00,200/- made u/s. 69A of the Act made vide assessment order. We have perused the records. The instant case relates to the rejection of alternate and inconsistent pleas of the assessee. As far as the income-tax matters are concerned, an assessee can take different stands at different times but cannot take contrary stands in the same case. Hon'ble Supre....