2026 (4) TMI 842

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.... For the Appellant: By Advs. Dr. K.P. Pradeep, Shri. T.T. Biju, Smt. Smitha Gopinath, Smt. T. Thasmi, Smt. M.J. Anoopa. For the Respondent: By Advs. Sri. P.G. Jayashankar, Shri. Navaneeth. N. Nath, Additional Standing Counsel, Income Tax Department. JUDGMENT PER DEVAN RAMACHANDRAN, J 1. We are considering these appeals together, since the constitutive issues involved are analogus; whi....

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.... in support of the source of cash deposit made. However, the AO had observed certain contradictions in the explanation offered by the appellant. These contradictions were not rebutted by the appellant either before the AO or before the CIT(A) and no attempt was made even before us rebutting the contradiction noted by the AO in the explanation. In the circumstances we are of the considered opinion ....

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....ondent, in response, however, submitted that the impugned orders are irresponsible and without error because, the learned Tribunal has conclusively found that the contradictions observed by the Assessing Officer, and which were found to be valid by the CIT (appeals), has not even been contested by the appellant before it. He argued that, when there was a complete lack of contentions from the side ....

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.... judgment would suffice. 10. But, it is the specific case of Dr. Pradeep K.P - learned counsel for the appellant, that there are several issues in the three cases which are not in common; but which have not been even considered. 11. That apart, as indicated above, the learned Tribunal has merely said that the Assessing Officer had observed certain contradictions, but without expatiating it, ....