2026 (4) TMI 270

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....J KUMAR CHAUHAN, JUDICIAL MEMBER: The appeal is directed against the order dated 30.10.2025 of Ld. Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre, Delhi [hereinafter referred to as the "CIT(A)/NFAC"] passed u/s 250 of the Income Tax Act, 1961 [hereinafter referred to as "the Act"] wherein the appeal of the assessee was partly confirmed and addition made by the AO vide Asse....

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....ng Officer was not satisfied with the explanation and held that the assessee failed to substantiate the source of such deposits with proper supporting evidence. Accordingly, the entire cash deposits Rs.9,25,46,846/- were treated as unexplained money u/s 69A of the Act and added to the income of the assessee. Consequently, the assessment was completed u/s 143(3) r.w.s. 144B of the Act determining t....

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....ter excluding one of the ICICI Bank Account no. 092905000532 is only Rs. 5,14,56,911/- and the same were sufficiently sourced from cash generated out of cash sales and cash withdrawals totaling to Rs. 6,06,23,576/-. I have considered the assessee's submissions. Even though, there are merits in the argument's of the assessee, but it is not possible to make one to one reconciliation whether Cash Dep....

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....ithdrawals but it is not possible to treat the same as fully explained. Therefore, to safeguard the interests of the Revenue, 10% of balance Cash Deposits are hereby treated as from unexplained sources. Thus, the addition to this extent which comes to Rs. 24,20,767/- is hereby confirmed as unexplained money and the balance addition is hereby deleted. To sum up, out of the total addition of Rs.9,25....