2025 (11) TMI 1889

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....n of income showing total income at Rs. NIL. In this case, information was received from the DDIT(Inv.), Kolkata dated 01.03.2019 regarding high value deposit and withdrawal cash transactions in the current account. During the investigation carried out by the Investigating Wing, KYC and Bank statement was taken wherein it was found that the debit of Rs. 19,62,843/- and credit of Rs. 20,00,000/- for the period from 01.04.2011 to 31.03.2012 were reflected. However, in response to 142(1) of the Act, the assessee submitted that the firm was created to purchase of immovable properties for carrying on the business of undertaking, developing and building housing projects. The assessee failed to provide the explanation of huge cash withdrawal of Rs....

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....y the ld. Assessing Officer in the assessment order as the assessee did not respond to the SCN in support of its claim issued by the ld. Assessing Officer inspite of several requests to explain as to why the cash deposited money of Rs. 20,00,000/- should not be treated as unexplained money. 4. On being aggrieved, the assessee preferred an appeal before the ITAT and raised the following grounds:- (i) That the Appellate Order dated 29th August, 2024 passed by the Ld. National Faceless Appeal Centre, Delhi under section 250 of the Income Tax Act, 1961 is without jurisdiction, illegal, invalid and bad-in-law and liable to annulled. (ii) That the learned National Faceless Appeal Centre, Delhi erred in dismissing the Appeal o....

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....ional Faceless Appeal Centre, Delhi is against law and facts of the case. 5. I have heard both the sides. It was the submission of the ld. Counsel for the assessee that the assessee-firm was created to purchase of immovable properties for the carrying on business of undertaking, developing and building housing projects. The assessee-firm mainly received fund from the non-resident partner by internet transfer from his HSBC Account. He further submitted that one of partners Shri Manish Modi transferred for an amount of Rs. 20,00,000/- on 29.07.2011 by RTGS from his HSBC Bank Account as capital introduction to the firm. The assessee was asked to submit the source from where the person deposited the money. The assessee-firm furnished the Ban....