2025 (10) TMI 405

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....ier, CA For the Respondent : Smt.Leena Lal, Sr.AR ORDER PER PRAKASH CHAND YADAV, JM : The present appeal of the assessee is arising from the order of the learned Commissioner of Income-tax (Appeals) dated 10th November, 2022 and it relates to the assessment year 2016-2017, having DIN & Order No.ITBA/NFAC/S/ 250/2022-23/1047206720(1). 2. The brief facts as coming out from the orders ....

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.... Gift from Mother 1,500 3. Assessee further explained to the A.O. that the source of the fund is the interest accrued to the assessee on the deposits made by the assessee, which deposits were duly offered for taxation in assessment year 2010-2011 onwards. Further clarifying, the assessee contended that these amounts were not included in the capital in the preceding years and the same are inc....

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....e appeared before the Ld.CIT(A) also argued the additions on merits. However, the Ld. CIT(A) could not find any force in the arguments of the assessee and partly allowed the appeal of the assessee. 5. Still aggrieved with the action of the ld.CIT(A), the assessee has come up in appeal before us and has raised 13 grounds of appeal, which are related to the additions of Rs. 85,94,268. The learned....

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....ttled position of law that the A.O. cannot add previous years credits as unexplained credits u/s.68 of the I.T.Act. In other words, the opening balance figures cannot be added u/s.68 of the I.T.Act since the purport of sec.68 is meant only for the current year's credit. The Revenue is not remediless. In case the Revenue wants to examine the previous years' financials under scrutiny, there are seve....