2025 (12) TMI 1827

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....for Mr. N.V. Balaji. For the Respondent : Mr. B. Ramana Kumar, Senior Standing Counsel. ORDER The petitioner received notice dated 21.03.2022 under Section 148A(b) of the Income Tax Act, 1961 (the I-T Act). The notice alleged that the assessee had deposited cash of Rs. 25,90,000/- and made a time deposit of Rs. 27,00,614/- during financial year 2014 - 2015 corresponding to asses....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....herein that the details of the bank statement needs to be verified. 3. Mr. B. Ramana Kumar, learned senior standing counsel, submits in reply that the assessee is under an obligation to establish that the amount escaping assessment is less than Rs. 50,00,000/-. He submits further that both the cash deposit and the time deposit qualify as assets and that the assessing officer was justified ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... not less than Rs. 50 lakhs." 5. It is evident from the above that the assessing officer failed to examine the bank statement so as to verify whether the cash deposits were used for purposes of creating the fixed deposit. In spite of the assessee providing the bank statement, this exercise was not undertaken. Without undertaking this exercise, it cannot be rationally determined as to wheth....