2025 (8) TMI 694

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....A/4) passed by the Income Tax Appellate Tribunal (for short "ITAT") in ITA No. 506/RPR/2024, was admitted for hearing on 12/06/2025 by formulating the following substantial question of law :- "Whether the ITAT is justified in upholding and sustaining the addition to the tune of Rs. 7,50,000 under Section 69A of the Income Tax Act, 1961 in the case of assessee/appellant for the assessment year 2017-18 on account of unexplained money by recording a finding which is perverse to the record ?" 2.The aforesaid question of law has arisen for consideration on the following factual backdrop :- (i) On 31/03/2018, the appellant/assessee had e-filed her return of income for assessment year 2017-18 declaring an income of Rs. 2,14,35....

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....vide impugned order dated 21/01/2025 (Annexure A/4) and a sum of Rs. 3,50,000/- has been deducted from the total amount of unexplained money i.e. Rs. 11,00,000/- relying upon the CBDT Instruction No. 3/2017 dated 21/02/2017, feeling aggrieved and dissatisfied by which, the instant appeal has been preferred by the appellant/assessee. 3. Mr. Siddharth Dubey, learned counsel for the appellant/assessee, would submit that CBDT Circulardated 21/02/2017 has not been complied with in its letter and spirit by learned ITAT, particularly, Clauses 1.1 and 1.3 which relates to Source Specific General Verification Guidelines and the appellant's Bank account statement for three financial years and return of income for six financial years have not been ....

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....e said amount, sustained the addition of Rs. 7,50,000/- with her income, however, the Standard Operating Procedure (SOP) ought to have been followed by the Assessing Officer and verification ought to have been made in terms of Clause 1.1 and 1.3 of the aforesaid CBDT Circular dated 21/02/2017, which provides Source Specific General Verification Guidelines and states as under:- Source Specific General Verification Guidelines 1. Cash out of earlier income or savings 1.1 In case of an individual (other than minors) not having any business income, no further verification is required to be made if total cash deposit is up to Rs. 2.5 lakh. In case of taxpayers above 70 years of age, the limit is Rs. 5.0 lakh per person.....