2025 (10) TMI 570

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..... AR ORDER PER K. NARASIMHA CHARY, J.M: Aggrieved by the order dated 27/09/2024 passed by the learned Addl / Joint Commissioner of Income Tax (Appeals)-8, Mumbai ("Ld. CIT(A)"), in the case of Venkatesham Avula ("the assessee"), assessee preferred this appeal. 2. Briefly stated facts are that the assessee is an individual and filed his return of income for the AY 2017-18 on 23.03.2018 declari....

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....ation of income at 12% of the cash deposits is not sustainable. He has taken us through the margin of net profit would be around 4% to 4.5%. According to him, the average percentage of the business of the assessee is approximately 6%. He pleaded that in terms of section 44AD, it would be reasonable to estimate the income of the assessee at 6% on the total deposits. 5. Learned DR placed reliance o....

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....he Act on the reason of eligibility factors. But the learned CIT(A) directed the learned Assessing Officer to adopt net profit at 12% on the total cash deposits. Assessee claims that the entire cash deposits are nothing but the business receipts. 7. Learned CIT(A) accepted that the total deposits made in cash in bank account during the FY 2016-17 are the business receipts of the assessee. The tur....