TaxTMI 
TaxTMI 
2025 (8) TMI 943
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....as been deposited into bank instead of Rs. 10,09,28,800/- as the AO established in his order. 2. During the FY 2013-14, total cash deposit into bank was Rs. 20,63,300/- & total cash withdrawals from bank was Rs. 19,87,650/- this means assessee had deposited the same cash which was earlier withdrawn from bank. But CIT (Appeals) allows only Rs. 3,10,000/- as cash withdrawn. 3. CIT(Appeals) had allowed a cash balance of only Rs. 2,00,000/- out of the previous years savings which seems very much on lower side booking to the status of the assessee. Also assessee is a regular tax payer since last 10 years. 2. The brief facts of the case are that the assessee has not filed his return of income for AY 2014-15 despite having hug....
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....ated 26.02.2022 was issued to the assessee providing final opportunity to provide requisite information/details. Since no response was made by the assessee, the AO completed the assessment under section 144 of the IT Act, 1961 by making an addition of Rs. 1,09,28,800/- as assessed total income of the assessee. Aggrieved by the order of AO, the assessee preferred appeal before the ld. CIT (Appeals). The ld. CIT (Appeals) considering the submissions of the assessee, partly allowed the appeal of the assessee. Now, being aggrieved by the order of ld. CIT(A), the assessee has come in appeal before us. 3. Before us, none appeared on behalf of the assessee. The ld. A/R sent his written submission and requested to consider the same, which are re....
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....09.13 6000 24.06.13 6000 18.09.13 19000 17.08.13 3000 25.11.13 7000 19.08.13 2000 06.12.13 12000 20.08.13 4000 19.12.13 18000 09.09.13 3000 23.01.14 65000 10.09.13 2500 10.02.14 910000 24.09.13 6450 11.02.24 755000 01.10.13 7000 28.02.14 38000 05.10.13 20500 2063300 07.10.13 272000 12.10.13 10000 14.10.13 10000 16.10.13 57000 18.10.13 4000 01.11.13 2000 04.11.13 6000 11.11.13 8000 18.11.13 3000 19.11.13 2000 19.12.13 15000 20.12.13 2000 26.12.13 4000 30.12.13 2000 17.01.14 2000 24.01.14 52500 27.01.14 8000 29.01....
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....raises questions about the assessee's compliance with tax obligations. 4. Cash Deposits and Withdrawals : Specific cash transactions, including a cash withdrawal of Rs. 13,18,000 on 28.02.2014, and no deposits after this date, is against the assessee's grounds of appeal. B. Request for consideration of ld. CIT(A) Order dated 29.12.2023. Cash Deposits It is humbly submitted that theorder of ld. CIT(A) may be considered in this regard. The relevant part is reproduced as under for your kind reference : (page no. 4 &5): " I am not able to understand from which & what unknown sources, AO came to the conclusion that I had deposited a sum of Rs. 1,09,28,800. My bank statement is attache....
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.... The appellant has stated tht the source of cash deposit is from earlier withdrawals and savings. From the bank statement, the entries of cash withdrawals over Rs. 20,000 are as follows : * 07.10.2013 Rs. 2,70,000 * 16.10.2013 Rs. 40,000 * 28.02.2014 Rs. 13,78,000 However, there is no cash deposit entry after 28.02.2014, therefore, the same cannot be the source of cash deposits made in earlier dates. The balance withdrawal of Rs. 3,10,000 can be considered as a source of the cash deposits. Further, it will be reasonable to give an allowance of Rs. 2,00,000 for past savings. Thus, the amount of cash deposit of Rs. 5,10,000 is considered as explained, being out of cash withdrawals and past savings. Acc....
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.... questioning the legitimacy of the claimed sources. e. Insufficient Evidence for Past Savings : Given that no source of income has been provided by the appellant during the year, the claim for the benefit of past savings holds no merit. Prayer: It is humbly submitted that the appellant's failure to comply with tax regulations, coupled with the lack of credible evidence to support the claims made, warrants the rejection of the appeal. The integrity of the tax system must be upheld, and the revenue's position should be maintained to ensure compliance and accountability." 5. We have heard the ld. D/R and perused the written submissions of both the parties. All the grounds involved relate to same i....