TaxTMI 
TaxTMI 
2025 (6) TMI 1832
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....er Section 250 of the Income Tax Act, 1961 (hereinafter referred to as the "Act") and relates to Assessment Year (A.Y.) 2017-18. 2. The facts of the case are that the assessee is an individual, running business activity in proprietorship concern of manufacturing and trading of Gold, Silver and ornaments made thereof. The assessee filed return of income for the impugned year declaring income of Rs. 4,72,880/-. During the year under consideration, the assessee was noted to have deposited cash during demonetization period, from 8t h November, 2016 to 30t h December, 2016, of Rs. 42,00,000/- (in Specified Banned Notes) in his account maintained with State Bank of India, Nr. Dharnidhar Derasar, Ahmedabad. Marking this to be a suspicious activ....
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....gly added from his business activity. He rejected the books of accounts maintained by the assessee. The increase in cash sale in the pre-demonetization period as compared to the previous year was treated as income from other undisclosed sources since it was this increased turnover which was attributed by the assessee as the source of cash deposited in the bank. The pre-demonetization cash sales for the impugned year was noted to be Rs. 44,60,540/- while that of the immediately preceding year for the same period was noted to be only Rs. 2,05,006/-. The difference accordingly of the two amounting to Rs. 42,55,534/- was added to the income of the assessee as income from other undisclosed sources. 3. The AO further noted the assessee to have....
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.... Ld. CIT (A) has erred in law and on facts in upholding addition made by the Ld. A.O. of Rs. 35,00,590/ - U/ S 68 of t he Act. 5. The Ld. CIT (A) has erred in law and on facts in upholding disallowance ma de by the Ld. A.O. of Rs. 10,010/ - being 50% of Rs. 20020/- u/s 37 of the IT Act, 196 1. 6. The Ld. CIT (A) has erred in law and on facts in upholding disallowance made by the Ld. A.O. of Rs. 10,04,732/ - being 25% of Rs. 40.18. 929/- u/s 37 of the IT Act, 1961. 7. The appellant craves liberty to add, amend, alter or modify all or any grounds of appeal before final appeal." 5. The assessee has also raised additional ground before us vide letter dated 20.12.2024 as under: "1. The assessment order pass....
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..../s. 68 of the Act for the same having remained unexplained. The contention of the Ld.Counsel for the assessee was that all these facts were pointed out to the Ld. CIT(A) in the submissions made in writing before him, a copy of which was placed at paper book page nos. 72 to 98. He contended that the submissions were substantiated with the return of income filed by the assessee showing income returned from business activity u/s. 44AD of the Act. Copy of the computation of income was filed before us a paper book page no.1 to 3. He contended that despite the assessee pointing out the above facts none of these facts were considered by the Ld. CIT(A) while adjudicating the grounds raised by the assessee before him. 8. Ld. DR was unable to cont....