2024 (4) TMI 1295

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....s the following substantive grounds in the instant appeal : 1. "On the facts and circumstances of the case and in law the order passed by Ld. CIT Appeal NFAC is bad in law on various counts and that the same should be set aside. 2. On the facts and circumstances of the case and in law the Ld. CIT Appeal NFAC has erred in confirming the order passed by the AO being violative of natural justice and thereby is bad in law and that the same should be set aside. 3. On the facts and circumstances of the case and in law the Ld. CIT Appeal NFAC has erred in confirming the addition of Rs.14,50,000/- without appreciating the material available on record and that the addition made by the AO, so confirmed by the CIT Appeal NFAC should be deleted. ....

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....icultural income, lease rent and cash in hand as on 08.11.2016. The appellant submitted before the AO that she was accumulating cash from past years for bearing medical expenses of her husband in case of emergency. The AO was not convinced with the explanation of the appellant. According to the AO, the appellant has shown only Rs. 28,620/- during the current year as agricultural income. The AO examined the appellant's version on Hunman Probability Test and rejected her explanation. According to the AO, it is human tendency that a person who possesses a large amount of cash in hand, will deposit the same into the bank account immediately, once he comes to know that the currencies which she holds/possesses are banned by the prescribed aut....

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....ars. The appellant submitted that she was holding cash in hand for medical emergencies of her husband who had been seriously ill and bed ridden. I have considered the submission of the appellant and the assessment order. The appellant has submitted computation of income, Capital account and balance sheet for the period relevant to AY 2017-18. But the appellant has not submitted any bank statement for the previous years and current year to substantiate her claim that she had withdrawn cash of Rs. 13,00,000/- during the year 2013 to 2014. Considering her own argument that her husband was seriously ill even if she had withdrawn cash from bank it is highly likely that the cash has been expended on her husband's illness. In absence of any sa....