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2025 (6) TMI 1383

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....rder dated 31.05.2021 passed u/s 143(3) of the Act pertaining to assessment year 2019- 20. 2. Brief facts of the case are that the assessee is an individual and was inspected by Air Intelligence Unit (AIU) of the Investigation Wing in Chennai when he was travelling from New Delhi to Chennai by Jet Airways on 13.09.2018. During the course of search by AIU unit, the assessee was found in possession of cash of INR 15 Lakhs. Thereafter, the case of the assessee was centralized with the ACIT, Central Circle-14, New Delhi. The assessee has filed the return of income in year under appeal on 31.08.2019 declaring total income of INR 3,45,110/-. Notice u/s 143(2) of the Act was issued on 18.01.2021 and thereafter, notices under section 142(1) were i....

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....rities below is wrong, illegal, misconceived, unjustified and bad at law therefore it should be quashed. 2. On the facts and in the circumstances of the case and in law, the authorities below have erred in charging interest u/s 234B. The action of the authorities is wrong, illegal, misconceived, unjustified and bad at law therefore it should be quashed. 3. The appellant craves the right to add, submit, alter or withdraw any or all grounds of appeal before or on the date of hearing. 6. Before us, the Ld.AR for the assessee reiterated the arguments put forth before the lower authorities with respect to the sources of the cash deposits made in the bank account. It is further submitted by Ld.AR for the assessee that the total cash of IN....

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.... as INR 8,000/-; 5,000/-; 49,500/-; 49,000/-; 48,900/-; 20,000/-; 15,000/-; 20,000/-; 20,000/-; 20,000/-, 20,000/- and so on and in all on total 16 occasions, cash was received in different sum which were deposited on the same day or on subsequent date by the assessee. 9. From the perusal of the affidavit filed by the father of the assessee, it is seen that only source of cash with the father was monthly contribution of INR 12,000/- given by the assessee and his other two brothers. Out of the said cash, parents of the assessee meet out their day to day expenses thus it cannot be acceptable that the father of the assessee was having cash of INR 3,67,400/- available with him after meeting out their day to day needs. Further, it is seen that ....