2025 (2) TMI 1810

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....024. 2. The assessee in this appeal is aggrieved by the action of the Ld. CIT(A) in confirming the addition of Rs. 6,90,75,400/- made by the Assessing Officer (hereinafter referred to as "the AO") u/s 69A of the Act on account of alleged unexplained cash deposits made in the bank accounts of the assessee. 3. Brief facts of the case are that the assessee did not file any return of income for the Assessment Year (AY) under consideration. The AO received information that there were cash deposits to the tune 6,90,75,400/-in the two bank accounts of the assessee during the financial year under consideration. He therefore, show caused the assessee as to why the assessment be not reopened and the aforesaid deposits be not treated as unexplai....

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....said commission income of Rs. 69,075/- for taxation. The disclosure made by the assessee was accepted by the Department. The assessee paid the due taxes, surcharge and penalty etc. @ 45% of the disclosed income. Apart from that the assessee had also declared some more commission income at Rs. 6,54,100/- in respect of financial year 2012-13 relevant to AY 2013-14, another commission income of Rs. 1,26,100/- and Rs. 80,000/- earned during AY 2012-13 and 2015-16 was declared under the said IDS 2016. The source of such income emanating from the cash deposits in the banks was clearly explained and exhibited in the disclosure petition. The Department accepted the disclosure and issued certificate of discharge of liability. After so many years, th....

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....u/s 148 of the Act, the assessee had already declared in the IDS Scheme that he had earned commission income in respect of bank transactions routed through his bank account. The said disclosure already stood accepted by the Department. The assessee in the said disclosure, had also mentioned about the sources of income disclosing the same was income of the assessee on account of commission received for the bank transactions done by other persons through his bank accounts. The Ld. Counsel for the assessee has brought our attention to relevant paras of the draft assessment order to show that information was given to the AO not only by the assessee but also by the bank that after deposit of the cash amounts in the bank account of the assessee, ....