2025 (6) TMI 1939

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....YADAV, JUDICIAL MEMBER: Present appeal of the assessee is arising from the order of ld. CIT(A)-2 Panaji dated 29.2.2024 having DIN & Order No.ITBA/A/APL/CIT(A),Panaji-2/10406/2018-19 and relates to assessment year 2019-20. 2. Brief facts of the case as coming out from the orders of authorities below are that the assessee is an individual and engaged in the business of wholesale and retail tradin....

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....ership of the cash found at the premises of the searched person. It is also admitted by the assessee that no withdrawals of such amount have been made by the assessee from his bank accounts. The only explanation on the assessee vis-à-vis source of this case is concerned is that the amount is receipt of sale accrued from trading of tyres. Besides this, gold coins of 60 gms. was also found at....

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....d the view of the AO. 4. Aggrieved with the order of AO, the assessee has come up in appeal before us and reiterated the arguments made before the ld. CIT(A) and the AO. The main thrust of the argument of assessee's counsel is that the source of this Rs.36 lakhs was sale receipts from tyres business and hence the same is taxable at normal rates instead of 60%. 5. Ld. D.R. appearing on behalf of ....

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....position of fact that during the course of search & survey, this receipt of Rs.36 lakhs has not been found mentioned in the books of the assessee. Further, the assessee has not even disclosed this while filing the original return, which has been filed much after the date of search and survey. It is pertinent to note that neither in survey nor in search proceedings at the premises of third party an....