2025 (7) TMI 1572

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....Addl. CIT ORDER PER RAJ PAL YADAV, VP The assessee is in appeal before the Tribunal against the order of ld. CIT(Appeals) dated 20.12.2023 passed for assessment year 2012-13. The assessee has raised two grounds of appeal, wherein he has pleaded that ld. CIT(A) has erred in confirming the re-opening of assessment and addition of Rs. 1,26,00,000/- added by the AO with the aid of Section 69A....

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....t. Amar Kaur, who was the primary account holder and the assessee is secondary account holder. It was contended that the money was deposited by his mother and not by the assessee. The mother of the assessee was expired. The ld. AO was not satisfied with the submissions of the assessee. He made an addition of Rs. 1,26,00,000/- on account of deposits made in the Saving Bank Account with HDFC Bank. ....

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.... of page 19 would indicate that mother of the assessee has agreed to sell 12 bighas of agriculture land comprised in Khatoni No. 22-25 Khasra No. 307 (4-0) 308 (4-0) and 310 (4-0). This was agreed to sell for a consideration of Rs. 4,02,00,000/- to Shri Jyotinder Singh Cheema, S/o Shri Inderjeet Singh Cheema, resident of 1534, Sector 34, Chandigarh. The assessee has taken advance from the vendor. ....

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....l details of the payments received under the Sale Agreement which was ultimately reflected in the Sale Deed. Thus, the mother of the assessee was having sufficient source for explaining the deposits in the bank account. The assessee has not been doing any other business which could have generated this much of money to him and the AO could be goaded to disbelieve the version put-forth by the assess....