2026 (3) TMI 329

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.... "1. For that the Ld CIT(A) was not justified in confirming the order of the AO in a hasty manner without appreciating the facts and documents on record. 2. For that the addition made for Rs. 52,16,169/- U/s 69A is fit to be deleted since the source of the same was duly explained before the lower authorities. 3. For that the lower authorities have failed to consider that there was a interbank transaction of Rs. 9,64,788/- and that Rs.45,00,000/- was unsecured loan received during the year which was repaid back in the year itself. As such, if the credit of such entries is given, there would be no difference between the total bank credits and the turnover disclosed. As such, the addition made for Rs. 52,16,169/- and confirm....

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....he bank Account No. Cash Deposit ICICI Bank 114905000840 Rs. 1,13,02,248/- State Bank of India 33814279405 Rs. 83,81,118/- Canara Bank 0377101013376 Rs. 71,105/- Total   Rs. 1,97,54,471/-   The total credit in the bank accounts Rs. 5,65,90,741/- Less: rejection of cheque in account No. 840 with ICICI Bank Rs. 6,06,625/-   Rs. 5,59,84,116/- Less: Cash deposit Rs. 3,68,36,270/- Deposit other than cash Rs. 1,91,47,846/- Gross sale consideration Rs. 5,08,61,576/- Less: Deposits other than cash Rs. 1,91,47,846/-   Rs. 3,17,13,730/- Add: Opening cash in hand Rs. 16,100/-   Rs. 3,17,29,830/- Less: closing cash in han....

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....rbank transfer and unsecured loans received during the year. * We are attaching herewith the ledgers for unsecured loan of Rs. 45,00,000/- at Page 3-4 from which it can be seen that the assessee received unsecured loan during the year and repaid back the same. * There was inter-bank transfer of Rs. 9,64,788/- during the year which can be verified from the bank statements of the assessee copy of which is at Page 5-13. From Page 05 & 08 it can be seen that Rs. 1,75,000/- has been transferred from Canara Bank to ICIC Bank on 19/12/2016. Similarly from Page 10 & 13 it can be seen that Rs. 4,25,000/- has been transferred from ICICI Bank to SBI on 08/03/2017. Lastly from Page 07 & 11-12 it can be seen that a sum of Rs. 1,50,000/....