2025 (12) TMI 921

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..... The assessee has raised the following grounds of appeal: "1. The Ld. CIT(A) erred in rejecting the appellant's application under Rule 46A of the Income Tax Rules, 1962, for the admission of additional evidence. The additional evidence was crucial for substantiating the appellant's claims. By not admitting this evidence, the CIT(A) has deprived the appellant of a fair and just opportunity to substantiate its case, thereby violating the principles of natural justice. 2. The CIT(A) erred in confirming addition of Rs. 2,07,56,750/- being the deposit made in Bank Account were legitimate business income from Petrol pump which were duly recorded in books of Accounts. It is therefore submitted that, the addition so made ....

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....ted as unexplained money under section 69A of the Act and the same was added to the total income of the assessee. The Assessing Officer also observed that the assessee had not co-operated during the proceedings and had suppressed material facts relating to cash transactions. Accordingly, the assessment was completed under Section 143(3) by assessing total income at Rs. 2,08,51,110/- and initiating penalty proceedings under Sections 270A and 272A(1)(d) of the Act. 4. In appeal, the assessee contended before the CIT(A) that the cash deposits were fully explained and were from cash sales from the petrol pump business carried on by the assessee. The assessee claimed that the deposits were duly recorded in the books of account and supported b....

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....Accordingly, the CIT(A) upheld the addition made by the Assessing Officer under Section 69A of the Act for a sum of Rs. 2,07,56,750/- on the ground that the cash deposits remained unexplained and unverifiable. The CIT(A) also confirmed the applicability of Section 115BBE to such deemed income, holding that the nature and source of the deposits were not established and therefore could not be taxed under any head of income specified in Section 14 of the Act. Thus, CIT(Appeals) dismissed the appeal of the assessee and sustained the additions made by the Assessing Officer. 5. The assessee is in appeal before us against the order passed by CIT(Appeals) dismissing the appeal of the assessee. 6. We have heard the rival contentions and peruse....