2026 (1) TMI 944

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... dated 04.05.2023, confirmed by Learned CIT(A), an addition of Rs. 76,31,100/- on account of "unexplained money" was made, while attracting provisions of Section 69A of the of the Income Tax Act, 1961 (hereinafter referred to as "the Act"). Said addition came to be made, as the Assessing Officer found that the assessee had deposited a sum of Rs. 76,31,100/-in cash, in following three banks, and that the assessee had failed to furnish reply to the show cause notice issued for the purpose of assessment proceedings:- Sr. No. Name of the Bank Account No. Amount (in Rs. ) 1. The Kota Central Cooperative Bank Ltd. 27006111130014325 32,46,300/- 2. The Kota Central Cooperative Bank Ltd. 27006111130014324 33,01....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....r is framed 6. Since the assessee neither furnished any reply to the notices nor furnish any details, the Assessing Officer was of the view that the assessee had deposited the above said amounts in cash with the above named banks, but the same remain unexplained, and as such, he proceeded to make addition of the said amount to the total taxable income of the assessee. Assessee comes up before Learned CIT(A) 7. As notice above, the assessee opted not to participate in the assessment proceedings, despite notices. But, he challenged the assessment order by filing an appeal on 16.10.2023. 8. Record reveals that Learned CIT(A) noticed that the appeal filed by the assessee was presented 135 days after the prescribed period of limitati....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....d order that only an unverifiable photo copy of a document purported to have been issued by the bank was produced before him, in the appellate proceedings; that said document was not produced during assessment proceedings nor subjected to any independent confirmation; no customer/master print-out, KYC records or sworn statement of any Bank Officer was furnished; that said bank account was traced on the basis of PAN linkage, and that the denial by the assessee in this regard was an afterthought. 12. As regards remaining deposit of Rs. 43,29,800/-, Learned CIT held that the same also continued to be unexplained. 13. With the above said observations, Learned CIT(A) dismissed the appeal filed by the assessee. 14. Ld. AR for the appella....