2025 (9) TMI 1479

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....dvocate For The Revenue : Dr. Ranjit Kaur, Addl.CIT, Sr.DR ORDER PER RAJ PAL YADAV, VP The assessee is in appeal before the Tribunal against the order of the Commissioner of Income Tax (Appeals) [in short 'the CIT (A)'] dated 28.02.2024 passed for assessment year 2017-18. The assessee has taken seven grounds of appeal, but the grievance of the assessee revolves around a single issue na....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....21 lacs were also found to be deposited but this was deposited during demonetization. The stand of the assessee is that both amounts cannot be segregated. It also pertains to the business of the assessee and on account of illness, he could not file the return in time. However, ld. AO did not accept this stand of the assessee to the extent of Rs. 21 lacs and assessed it separately and charged the t....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....iness receipts of the assessee and estimated the profit at 8%. We fail to understand as to why a different treatment has been given to a sum of Rs. 21,00,000/- which is also available in this very account only, there is a time difference of deposit but because this amount was deposited in different months i.e. during demonetization, it will not take a separate colour. It should also be made part o....