2025 (7) TMI 233

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....sed by the assessee are as under: "1. Whether on the facts and circumstances and in law, The Learned Commissioner of Income Tax (Appeals), NFAC has erred in confirming the action of assessing officer in making addition of Rs. 21,75,000/- as unexplained investment u/s 69 of the I.T. Act, 1961. 2.Whether on the facts and circumstances and in law, the learned CIT(A), NFAC has erred in confirming the action of assessing officer in invoking provisions of section 115BBE of the Act and thereby taxing the unexplained investment amounting to Rs. 21,75,000/- at 30 percentage. 3. It is therefore prayed that above addition made by assessing officer and confirmed by commissioner of Income tax (Appeals) may please be deleted. ....

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....Ltd., 134 taxmann.com 149 (Guj.). The CIT(A) did not accept the contention of the assessee and held that AO was justified in making the addition u/s 68 of the Act because the persons were of small means and cash deposits were made, which in turn were given as loans to the assessee. The CIT(A) has accordingly upheld the addition made by AO. 5. Aggrieved by the order of CIT(A), the assessee filed appeal before the Tribunal. The learned Authorized Representative (ld. AR) of the assessee filed a paper book containing 54 pages including written submissions before the AO and CIT(A), confirmation of accounts, ITR and bank statements of the lenders and bank statement of assessee reflecting repayment of loans. He filed another compilation of case....