2025 (8) TMI 522

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....Written Submission) For The Respondent : Shri Prateek Sharma, Sr. DR ORDER PER SHRI NARENDRA PRASAD SINHA, AM: This appeal is filed by the Revenue against the order of the Commissioner of Income Tax (Appeals)- 12, Ahmedabad (in short 'the CIT(A)'), dated 28.11.2023 for the Assessment Year 2021-22. 2. The brief facts of the case are that the assessee is a political part y and a searc....

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....bank account of the assessee was seized in the course of search operation. The AO had made protective addition of seized cash of Rs. 5,35,72,646/- in the hands of the assessee and the substantive addition was made in the hands of one Shri Saumil K. Bhadiadra. The assessment was completed u/s.153A r.w.s. 144 of the Act on 31.03.2022 at total income of Rs. 2,55,75,69,808/-. 3. Aggrieved with the ....

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....ed to the above extent." 5. The only ground taken by the Revenue is against the deletion of addition of Rs. 5,35,72,646/- in respect of seized cash. Shri Prateek Sharma, Ld. Sr. DR submitted that since the cash was found from the bank account of the assessee, the Ld. CIT(A) was not correct in deleting the addition made by the AO in this regard. No compliance was made on the part of the assessee....

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....as rejected by him. However, I find that this amount is part of the total deposit in the State Bank of India which has already been brought to tax in the hands of the appellant us 68 r/w 115DDE as Rs 19,37,62,858/- during AY 2020-21 & Rs 241,34,94,259/- for AY 2021-22 Without prejudice to the addition made in the hands of Shri Saumil Bhadiadra of this amount, addition of this amount again in the h....