AI OCR 
TaxTMI 
TaxTMI 
TaxTMI 
2025 (1) TMI 1629
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....er referred to as "the Act") vide order dated 16/12/2019 2. The grounds of appeal raised by the assessee are as follows: (1). The Ld. CIT(A) erred on facts as also in law by confirming the order issued by Ld. AO, Rajkot is bad in law and contrary to the facts of the case. (2). The Ld. CIT(A) erred in law and on facts by rejecting only opening cash balance without rejecting complete set of books of accounts prepared by the appellant. (3). The Ld. CIT(A) erred in law and on facts by not considering the fact that appellant's only source of income is from partnership firm and additional withdrawals made in previous years lead to subsequent accumulation of cash in hand. (4). The Ld. CIT(A) erred on fact by ....
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.... academic in nature or contentious in nature. However, to meet the end of justice, we confine ourselves to the core of the controversy and main grievances of the assessee. The solitary grievance of the assessee, in this appeal is that Ld. CIT(A) erred in confirming the addition of Rs. 2,50,000/-, made by the assessing officer. 4. Succinctly, the factual panorama of the case is that assessee before us is an Individual and had e-filed his return of income on 09-02-2018, declaring total income at Rs. 8,88,180/-. The return of income was processed by the Department u/s 143(1) of the Act. Later on, the assessee's case was selected for limited Scrutiny through CASS to verify the cash deposited during demonetization period. The assessee is enga....
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....sh deposit during the demonetization period (Amount in Rs. ) 1 KarurVysya Bank 22031550000018333 Rs. 2,50,000/- 2 KarurVysya Bank 2203155000017880 Rs. 14,00,000/- Total Rs. 16,50,000/- 6. On going through the return of income it was found that the assessee is owing only one bank account in the return of income and information of Rs. 2,50,000/- has been given for cash deposit, other cash deposit is of his family member in the name of Hema Ajay Bhansali with cash deposit of Rs. 14,00,000/-, however PAN of the assessee only has been updated in the bank account. Notice for detailed information was issued by the assessing officer to the Karur Vaisya Bank where reply was received that the asses....
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.... CIT(A), who has just reiterated the findings of the assessing officer and has confirmed the action of the assessing officer, therefore the assessee is in further appeal before us. 8. Learned Counsel for the assessee, submitted that Ld. AO made addition of Rs. 250,000/- on account of cash deposit during the demonetization period, despite of the fact that assessee had explained the source of the cash so deposited, stating that assessee withdraws Rs. 6,000/- from partnership firm and such amount was accumulated by the assessee in cash, and when the demonetization scheme has been announced, the assessee deposited the said amount in the bank account. The Ld. Counsel also submitted that part amount was deposited out of opening cash balance of....
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....hargeable to income tax. 11. However, we find that CBDT has issued instruction, to the assessing officers as to how to examine of the case of cash deposit during the demonetization period and in said circular the CBDT has explained and narrated facts that there should be blanked exemption of Rs. 2,50,000/- per person, vide instruction No. 03/2017, dated 21/02/2017, wherein CBDT has explained that in case of small assessees, like artisans, daily workers, housewives, and small assessees etc, then such small amount would not be questioned by the Ld. AO up to Rs. 2,50,000/- per person. Taking into account, the facts narrated above, we note that Instruction issued by the CBDT should be considered, vide Press Release dated 18.11.2016 and Guide....