2025 (6) TMI 1114

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....the Income Tax Act, 1961 ("the Act" for short) whereby the assessee's total income was assessed at Rs. 11,91,780/- as against returned income of Rs. 3,91,780/-. In the aforesaid assessment order, an addition of Rs. 8,00,000/- was made u/s 69A of the Act. The aforesaid amount of Rs. 8,00,000/- was made on account of cash deposited by the assessee in bank. The assessee, during assessment proceedings, submitted that the assessee himself and his wife, both were senior citizens, suffering from medical ailments and had to maintain reasonable amount of cash in hand (to meet emergency medical expenses). The assessee also submitted cash flow statement to explain the source of cash deposit in bank. Aggrieved by the addition made in the assessment ord....

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....11.2016. The appellant has submitted that the staggered cash deposits were made due to practical difficulties in standing in long bank queues post- demonetization. • The appellant contends that the Assessing Officer (AO) arbitrarily rejected the explanation without conducting a proper inquiry. • He argues that since Rs. 4,00,000/- was accepted as explained, the rejection of the remaining Rs. 8,00,000/- lacks consistency. • The appellant has relied upon various judicial decision wherein the cash deposits from past accumulated savings has been accepted, emphasizing that past financial behaviour should be considered while assessing unexplained cash deposits. (A.2) The learned Addl/Jt.CIT(A) did not con....

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....(A) also, in his aforesaid impugned appellate order, did not accept the assessee's submissions stating that the source of income, opening cash, cash flow statement, and withdrawals etc. submitted by the assessee were not supported by any concrete documentary evidence and that there was large inconsistency in facts and submissions made by the appellant. However, on perusal of the orders passed by the Assessing Officer and the learned Addl/Jt.CIT(A), it is found that there is nowhere any mention of what further (concrete/documentary) evidences were called for from the assessee by them. Further, the assessment records of the assessee for earlier years were available/ accessible for Revenue authorities for verification and yet no discrepancy ha....