2026 (4) TMI 270

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.... Kalra, Sr. DR ORDER PER RAJ 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 ....

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....withdrawals. However, the Assessing 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....

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....s That his total cash deposits after 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 on....

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....substantially sourced from cash withdrawals 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....