2025 (12) TMI 736

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....r.w.s. 144B of the Act for the Assessment Year (AY) 2017-18. 2. Revenue has raised the following grounds of appeal:- "1. On the facts and in the circumstances of the case, the Ld. CIT (A). NFAC failed to appreciate the facts of the case and without considering the same decided the case in favour of the assessee which is against the law and the order of the CIT (A) deserves to be set-aside. 2. The Ld. CIT (A), NFAC erred in law in holding that the total cash deposits of the assessee as a turnover and also erred in treating 5% of such cash deposits as income of the assessee. 3. The Ld. CIT(A), NFAC erred in appreciating the fact that even as per IT Act, 1961, presumptive income on such cash sales u/s 44AD is 8% o....

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....ee is an individual and did not file return of income for A.Y. 2017-18. Based on the information about deposits in the bank account held with Shri Renuka Mata Multi State Urban Cooperative Society, valid notices u/s. 148 and 142(1) of the Act were issued and served upon the assessee. In absence of any reply, Ld.AO made the addition for the total amount received from the bank account amounting to Rs. 99,73,439/- invoking section 69A of the Act. Further, Ld.CIT(A) on due consideration of the fact that assessee is in the business of purchase and sale of scrap from vendors and buyers and assessee earns commission on such transactions, partly allowed the assessee's appeal computing the net profit @ 5% on the alleged cash deposits observing as fo....