2025 (2) TMI 1896

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....inafter referred to as "the Act" for short], for Assessment Year (AY) 2017-18. 2. The solitary grievance raised by the Revenue reads as under:- "Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) was justified in deleting the addition of Rs. 1,04,06,448/- u/s 69A of the Act without appreciating the fact that the assessee failed to give any explanation about the nature and source of cash deposits." 3. The brief facts of the case are that the assessee is an individual. The assessee had not filed his return of income for the year under consideration. The Assessing Officer observed that the assessee had deposited cash of Rs. 11,89,500/- during the period of demonetization. Therefore, the assessee....

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....ur office wherein it is clearly stated that the profit margin on E-top up sales shall be 0.7% for the period of 2013 to 2017. Further, a plain analysis of the bank statements clearly portray that the entire amount deposited has been transferred to Vodafone west Ltd., which makes it evident that the entire sales proceeds has been transferred to Vodafone West Ltd. and the appellant does not have any other source of income." In view of the above submissions, the claim of the appellant that the deposit in the bank was made from agricultural income is not acceptable. It is also seen that the Appellant had transferred the amount received by him in his account to Vodafone. The appellant had furnished a certificate in the letter head of Vo....