TaxTMI 
TaxTMI 
2026 (2) TMI 1194
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....d under Section 148 dated 12th January 2021 and the order dated 2nd December 2021 disposing of the objections filed by the Petitioner to the reasons for reopening the assessment. The assessment year in question is A.Y. 2013- 14. 2. The Return of Income for A.Y.2013-14 was filed on 26th December 2013 declaring a total income of Rs. 17,50,690/-. Thereafter a notice under Section 142(1) dated 29th December 2015 was issued to the Petitioner raising certain queries with respect to cash deposits in various bank accounts as well as certain other issues. On 7th January 2016 the Petitioner files its response to the above notice explaining the cash deposits and its source. Thereafter, on 29th February 2016, during the course of assessment, a detai....
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....y of the reasons recorded. The reasons for reopening were accordingly furnished to the Petitioner on 28th June 2021. On 20th July 2021 the Petitioner filed its objections to the reasons recorded. Finally, the order disposing of the objections was passed on 2nd December 2021, a copy of which was provided to the Petitioner on 17th February 2022. It is in this light that the present Petition was filed by the Petitioner on 7th March 2022 challenging the notice issued under Section 148 as well as the order disposing of the objections. 5. From the record we find that the reasons recorded for reopening the assessment [for A.Y.2013-14] are from page 96 onwards. The first reason for reopening reads as under:- "As pointed out in the above....
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..../-. The Assessing Officer observed that neither any major amount was credited nor other amounts debited in the cash book. In light of these facts the Assessing Officer opined that to justify the expenses, the Assessee had made the said cash deposits in banks, out of his unexplained cash in hand of Rs. 5,74,72,858/-, which were nothing but unexplained cash credits and deposits in the hands of the Assessee under Section 68 of the Act. For the sake of convenience the reason for reopening assessment on this ground by the Assessing Officer is reproduced hereunder:- "2.2 Underassessment of Income: On perusal of the records, it is observed the following cash deposits have been made during the year in the Bank accounts maintained which are....
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....age 57 of the paper book. Against each of the entries mentioned in the questionnaire, an explanation was given, namely, that the amount deposited was out of the cash balance available in the cash book which was duly recorded in the books of accounts. Alongwith this explanation, the Petitioner also enclosed a copy of the cash book for the verification by the Assessing Officer. This exercise was done not only with reference to Kotak Mahindra Bank and NKGSB Bank, but also with reference to cash deposits as per the CIB details. After examining all this material, the Assessing Officer, being satisfied with the explanations furnished, did not make any addition in relation to the cash deposits in the scrutiny assessment proceedings under Section 1....