2025 (9) TMI 1305

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....n 144 r.w.s. 147 of the Income Tax Act, 1961 (hereinafter referred to as 'the Act'). 2. The brief facts of the case are that the return of income was not filed by the assessee for the A.Y. 2012-13. The AO had reopened the case under section 147 of the Act on the basis of information that there were cash deposits of Rs. 26,01,780/- in the bank account of the assessee and the assessee had also made investment of Rs. 10,00,000/- in bonds/debentures. Accordingly, a notice under Section 148 of the Act was issued on 31.03.2019, in response to which, the assessee had filed her return on 24.04.2019 declaring income of Rs. 2,49,840/-. In the assessment proceeding, however, no compliance was made by the assessee and the source of cash deposits and....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....d. CIT(A) has grossly erred in not accepting the returned income of the appellant considering it as afterthought. 4. On the basis of facts and circumstances of the case and in law, the Ld. CIT(A) has grossly erred to consider only cash deposits in the bank and for not considering the cash withdrawals from the bank. 5. On the basis of facts and in the circumstances of the case and in law, the Id. CIT(A) has grossly erred in confirming the addition of Rs. 10,00,000/- on the ground that appellant has made investment in bond and debenture despite knowing the fact that the payment for the same was made through proper banking channels and the same were from her daughter's bank account. Therefore, the addition of Rs. 10,00,000/- ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ities. The Ld. AR submitted that considering the fact that the investment in bond was made out of withdrawal from the account of the daughter, the Assessing Officer was not correct in treating the same as unexplained. 6. Per contra, Shri Nitin Kulkarni, Ld. Sr. DR submitted that only one truck was registered in the name of the assessee. Further, that the contention of the assessee that the entire cash withdrawals were redeposited in the bank account was not correct, considering the fact that the assessee must have incurred substantial expenditure towards fuel, driver's salaries and other expenses for running the trucks. He, therefore, strongly supported the orders of the lower authorities. 7. We have considered the rival submissions. ....