TaxTMI 
TaxTMI 
2025 (8) TMI 147
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....(AY) 2018-19. 2. The ground of appeal raised by the appellant is as follows: "The Ld. AO has made additions to dissolved firm having PAN: AAHFA4245J u/s. 69A of the Act making additions of all the credit transactions of Rs. 6,29,89,197/- in the HDFC bank account ignoring the facts submitted by the appellant and made order u/s. 144 of the Act. Further, the Ld. CIT(A) dismissed the appeal and confirmed the additions made by the Ld. AO." 3. The facts of the case in brief are that the assessee did not file its return of income for AY.2018-19. As per the information available in the category 'Non-filling of return (NMS)' on the insight portal of the department, it was found that assessee had deposited cash of Rs. 1,47,52,000/- in ....
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....e source of funds, ledger A/c. and other supporting evidences. The AO observed that the appellant failed to prove the source of cash deposits/other credits in the bank account with the result that aforementioned cash deposits/credits entries aggregating to Rs. 6,29,89,197/- made in the appellant's HDFC bank account remained unexplained. Consequently, aforesaid cash and credits aggregating to Rs. 6,29,89,197/- was added to the total income of the appellant u/s 69A of the Act as 'Unexplained money' and order u/s. 147 r.w.s 144 of the Income tax Act was passed on 30.03.2023. 4. Aggrieved by the order of the AO, the appellant preferred appeal before the CIT(A). The CIT(A) dismissed the appeal of the appellant by observing that the contention....
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....and cash deposit aggregating to Rs. 6,29,89,197/- in the HDFC Bank account bearing A/c No.50200024762393. 7. We have heard both the parties and perused the material available on record. We have also deliberated upon the decision relied upon by the ld. AR. We find that during the assessment proceedings, the AO had categorically asked the appellant to explain with evidence the source of credits in the HDFC bank account of Rs. 6,29,89,127/- including the cash deposits of Rs. 1,47,52,000/-. But the appellant continued to stress upon its submission that its business was converted to a new firm and return was filed with new PAN of the said firm. All the transactions in the impugned HDFC bank account are accounted for. The same reply was filed ....
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....93, has not been mentioned anywhere in the return of income. Only 3 other bank accounts were disclosed by Abdulbhai Kasambhai & Co. (PAN: AAVFA4614K), which are as under: Sr. No. Name of bank A/c. No. 1 Bank of Baroda 02480200000210 2 Union Bank of India 412501010036006 3 Union Bank of India 412505040077016 7.2 Further, no reasons or cogent reply has been given by the appellant as to why such huge financial transactions were undertaken by the appellant on the PAN of a non-existing entity even after 5 years of closure of business under the PAN: AAHFA4245J. This amply proves appellant's intention to evade payment of legitimate tax to the exchequer and avoid scrutiny of income tax department. 7.3 In it....