2025 (12) TMI 966

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....) for Assessment Year 2015-16. 2. The sole grievance of the assessee is as follows:- "That on facts and in law the learned NFAC-CIT(A) has grievously erred in confirming the addition of Rs. 1,03,43,401/- made as unexplained income of the appellant." 3. The brief facts of the case are that the assessee is engaged in the business of Vehicle Rental. The assessee filed return of income for the year under consideration on 15.02.2016 declaring total income at Rs. 3,63,630/-. The case was selected for scrutiny and notice u/s 143(2) of the Act was issued on 29.09.2016. The Assessing Officer, after verification of the details submitted, passed assessment order u/s 143(3) of the Act on 29.12.2017 and determined the income at Rs. 1,07,0....

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....n made by the Assessing Officer as unexplained income was not based on assumptions and presumptions and was made only after the assessee could not discharge the onus casted upon him to produce the evidences. 8. We have heard both the parties and perused the material available on record. We have gone through the submissions made by the assessee before the Ld. CIT(A). The submissions reveal that the assessee has sold equity shares during the F.Y. 2011-12 for a consideration of Rs. 2,26,63,648/- and disclosed the long-term capital exempt u/s 10(38) in the ITR for that year. The return for the F.Y. 2011-12 was selected for scrutiny and the Assessing Officer has assessed exempt income at Rs. 2,07,19,525/- and passed assessment order u/s 143(3....

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....; 66,300.00 -- 30.09.2014 Rate difference of $ 50,000/- 70,07,453.50 1,14,975.00 11.12.2014   1,16,469.68 -- 16.12.2014 Rate Diff. Of $ 1,14,975/- 1,22,800.00 2002.24 30.03.2015 -- 1,02,79,600.20 Total remittance from USA to India were credited in ICICI Bank 8.1 The assessee submitted copy of bank statement of SB a/c # 8501512977 with ICICI Bank, Anand Branch in which the remittance was credited and also submitted the bank statement of bank account in USA. The Assessing Officer has made an addition of Rs. 1,03,43,401/- holding that the assessee failed to submit the source of deposits in foreign bank account of $ 50,000 on 25.09.2014 and $ 1,15,000. It is undisputed that the asses....