2025 (6) TMI 1478

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....or A.Y. 2017-18. 2. The Assessee has taken the following grounds of appeal:- "1. Whether, on facts and in circumstances of the case and in law, Ld. CIT(A) erred in confirming the addition for Cash deposit of Rs. 54,50,000/- as unexplained money u/s. 69A of the act.? 2. Whether on facts and in circumstances of the case and in law, Ld. AO has erred in making assessment u/s. 143(3) of the act? Further, appellant craves leave to add, amend, alter or withdraw all or any ground of appeal." 3. The brief facts of the case are that the assessee filed return of income, declaring total income of Rs. 93,49,550/-. As per data available with the Assessing Officer, he observed that assessee had deposited cash of Rs. 54,50,000/- in her bank account....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....r old age assessee's mother also expired at Apollow Hospital Hyderabad on 22.02.2017. She further stated that this was also one of the reason for having requirement of cash on hand. The assessee has not submitted any supporting documentary evidence with regard cash expenses for medical treatment for her mother, cash expenses in travelling to Australia etc. Therefore, the contention of the assessee is not acceptable. The reason stated in her reply is in general nature, not justifiable and tenable. The assessee has not provided any supplying documents in support of her claim. 7. Considering the above facts and elaborate discussion held in the preceding paragraphs, it is confirmed that the assessee could not explain and establish the sou....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....s as asked by the A.O during the assessment proceedings were not provided in the appellate proceedings. Hence, reasons as given by the assessee holding huge cash with her are not supported by any documentary evidence. 4.3 In absence of any substantial documentary evidence in support of its grounds of appeal, I have no basis to take a contrary view in the appellate proceedings as I have no reason to interfere with the assessment order. As such, I do not find any infirmity in the order of Assessing Officer. Therefore, Addition of Rs. 54,500,000/- is hereby sustained on merits. Accordingly, Grounds No.1 and 2 are dismissed. 5. In the result, the appeal is Dismissed." 5. The assessee is in appeal before us against the aforesaid order passe....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ssee, was not available with the assessee for being redeposited in the same bank account. Accordingly, the Counsel for the assessee submitted that the source of cash deposit had been fully explained and accordingly, no addition was called for, looking into the assessee's particular set of facts. 6. In response, Ld. D.R. placed reliance on the observations made by the Assessing Officer and Ld. CIT(A), in their respective orders. 7. We have heard the rival contentions and perused the material on record. 8. It would be useful to reproduce the table of cash withdrawals and deposits made by the assessee from the said bank account during the period January 2016 to December 2016: Table 3 - Cash withdrawals & deposits from Jan 2016 Date Chequ....