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2025 (7) TMI 1435

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....ds of appeal in Form No. 36 are as under: "1. That the Learned Assessing officer, Ward 3(2), Ferozepur has wrongly made the addition to the tune of Rs. 12,62,000/- on account of bank deposits in the axis bank on the plea that it was not accounted for in the books of accounts whereas the assessee has filed both the bank statement of the accounts with the axis bank and Punjab national bank along with the ledger copy of the books of the accounts explaining each and every entry deposit and withdrawal of the bank in the books of accounts maintained during the financial year 2014-15 relevant to the asst year 2015-16 without seeing the documentary evidence filed online by the assessee during the assessment proceeding . Hence it is humbly ....

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....es. 3.2 In course of assessment proceedings, the assessee has responded by filing online replies alongwith written submissions, and with necessary documentary evidences including computation of income trading profit and loss account, balance sheet and copies of bank statements alongwith ledger a/c of traders with whom the assessee was engaged in the business of trading fruits and vegetable, (the assessee being the commission agent). It was also found by the AO that the assessee was engaged mainly with one party for the purpose of his wholesale business of earning commission i.e. with M/s Suresh Chandra Kalra and Co. and the total transactions executed with the said party amounting to Rs. 1.55 crores. It was further observed by the AO tha....

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.... Rs. 7,02,565/- already offered by the appellant on account of this party and without mentioning any comparable profit figures of similarly placed assessees, the AO went ahead to make addition of entire amount of Rs. 12,44,129/-. He further observed: " (a) The claim of the appellant was acceptable and no additions were required to be made to his income in respect of transactions of Rs. 1,55,51,616/- with M/s Suresh Chander Kalra & Co. Additions of Rs. 12,44,129/- made on this account are hereby deleted." 4.1 However, the ld. CIT(A) sustained the addition of Rs. 12,61,845/- on account of unexplained cash deposit in Axis Bank A/c XXXXX40416 by observing as follows: "(b) The claim of the appellant is not acceptable on t....

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.... A/c XXXXX40416 for the year under appeal are almost the same. 5.1 He further submitted copies of license issued by Mandi Karan Board of Katcha and pakka Arthiya in support of his contention that he is engaged in the business of earning commission from wholesale trading of fruits and vegetables. 5.2 The ld. AR of the assessee further submitted that the total cash deposit made on various dates in this Axis Bank A/c is basically collection of sale proceeds from various retailers to whom fruits and vegetables has been supplied. It is the retailers who deposit the money in cash in the assessee's bank account from various places were the goods has been supplied and the said amount is withdrawn by the assessee by cheques and payments are ma....