2025 (2) TMI 1385

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....cumstances of the case and in law the learned Commissioner of Income tax (Appeals) ("CIT(A)") erred in upholding the addition made by the Assessing officer to the income of the Appellant. The Appellant prays that the additions be directed to be deleted. 2. On the facts and circumstances of the case and in law the learned Assessing Officer erred in making addition of the cash deposit during demonetization period of Rs. 10,00,000/- and treating it as unexplained u/s 69A of the Act. Therefore the said order is illegal, void and unwarranted and it is prayed that the said addition be directed to be deleted. 3. Without prejudice to above, on the facts and circumstances of the case and in law the learned Commissioner of Income ta....

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.... brief are that the assessee is an individual and carrying on the business of running a shop in the name of MP Online Kisok Center. The assessee accepts amount from various customers for further deposit towards Telephone, Electricity, Tuition/Exam fees etc. Based on the reason that the cash of Rs. 12,17,000/- was deposited in the bank account held with SBI, Neemuch during 9.11.2016 to 31.11.2016 case of the assessee selected for scrutiny. The assessee did not file any return of income. Thereafter certain opportunities were given and notice u/s 142(1) of the Act was issued. Ld.A.O concluded the assessment by observing that except the alleged cash deposit of Rs. 10,00,000/- the remaining amount deposits at Rs. 70,17,572/- relates to the trans....

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....ion notes during the demonetization period and therefore the impugned addition deserves to be sustained. 8. I have heard rival contentions and perused the records before me. Admittedly the assessee is running MP Online Kisok Centre and is regularly making payments on behalf of its customers towards, electricity, telephone, mobile, examination fees etc. In the bank account maintained by the assessee total credit during the year was Rs. 80,17,572/- out of which Ld. A.O has accepted sum of Rs. 70,17,572/- as a genuine business transaction of MP Online services but denied to treat the amount of Rs. 10,00,000/- merely on the ground that it was received during the demonetization period. Though Ld. Departmental Representative has claimed that a....