2025 (7) TMI 40

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....Assessee has raised following grounds of appeal : "1. On the facts and in the circumstances of the case and in law, Ld. CIT(A) erred in not deleting the entire unlawful addition of Rs. 30,32,500/- made by AO on basis of conjectures and surmises being cash deposited into bank account from earlier available cash withdrawals which is not established to be utilised for any other purpose/ investment. 2. That on the facts and in the circumstances of the case and in law, Ld. CIT(A) erred in sustaining the addition of Rs. 15,32,500/- made by AO on account of cash re-deposited from available cash duly substantiated on the basis of self presumed reasoning. 3. That on the facts and in the circumstance of the case and in law,....

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....sessee requests for admission of the above ground." 4. The only grievance of the assessee is that ld.CIT(A) erred in sustaining the addition of Rs. 15,32,500/- for the alleged unexplained cash deposit in the bank account. By way of additional ground, assessee assailed the impugned order stating that ld.CIT(A) erred in confirming the action of AO invoking section115BBE of the Act inspite of the fact that the provision giving rise to calculation of tax on the income referred to in subclauses (a) and (b) of section 115BBE of the Act are effective from 01.04.2017. 5. Brief facts of the case are that the assessee is an individual and income of Rs. 5,40,480/- declared in the return of income for A.Y. 2017-18 furnished on 28.10.2017. Case se....

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....ofinance Limited Vs. ACIT in W.P.No.2078/2020 order dated 19.11.2024. 8. On the other hand, ld. Departmental Representative supported the orders of the lower authorities. 9. We have heard the rival contentions and perused the record placed before us. Firstly we will take up the issue on merit regarding addition of Rs. 15.00 lakh sustained by ld.CIT(A). In Ground No.2, assessee has inadvertently mentioned the addition sustained by ld.CIT(A) at Rs. 15,32,500/- however from perusal of the finding of ld.CIT(A) appearing on page 9, we find that ld.CIT(A) has only confirmed the addition of Rs. 15.00 lakh. 10. Now the issue before us is whether assessee has explained the nature and source of the alleged cash deposit. Our attention is draw....