2025 (10) TMI 291

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.... The Ld.CIT(A) has erred in law & failed to appreciate the facts and circumstances of the case by confirming the addition of Rs. 4,00,000/- pertaining to cash deposits in the month of October, 2011 and such addition made by Ld.AO is merely on basis of guess work and surmise. The Ld.CIT(A) and the Ld.AO erred in appreciating the explanation furnished by the assessee in respect of such cash deposit and made an addition which is against the provisions and spirit of the Act. The said addition be deleted and the assessee be granted just and proper relief in this respect. 2. The appellant craves to add, delete, alter, modify any of the grounds of appeal." Submission of ld.AR : 2. Ld.AR for the Assessee filed a paper book and submit....

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....ssment Order has specifically mentioned date of Initial Deposit which was pertaining mainly to FY 2005-06,2006-07. Ld.CIT(A) sustained the addition of Rs. 4,00,000/- only. The relevant paragraph of ld.CIT(A) is as under : "The submissions of the appellant are perused. The Assessee is having four savings bank accounts with Bank of India (as could be seen vide para no.3 of show cause notice dated 28.11.2019). The total cash deposits made in the all the bank accounts maintained with Bank of India during the FY 2011-12 relevant to AY 2012-13 was Rs. 9,70,000/-. The appellant has already shown agricultural income of Rs. 5,36,820/- for the year under consideration and has claimed that the cash deposit of Rs. 4,00,000/- made on 19.10.2011....