2026 (6) TMI 412

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.... who is an individual, did not file return of income for the A.Y. 2017-18. On the basis of information received under "Operation Clean Money", the A.O. noticed that, the assessee had deposited cash of Rs. 11,00,000/- during demonetisation period in his bank account maintained with SBI. Accordingly, notice under Section 142(1) of the Income-tax Act, 1961, dated 09.03.2018 was issued calling upon the assessee to furnish return of income for the A.Y. 2017-18. However, the assessee failed to furnish return of income either under Section 139 of the Act, or in response to notice issued under Section 142(1) of the Act. Therefore, the A.O. initiated proceedings under Section 144 of the Act. 3. During the course of assessment proceedings, the fat....

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.... the amount was deposited into the educational loan account of the assessee. 5. The Ld. CIT(A) after considering the submissions of the assessee and also taking note of the reasons given by the A.O. to treat cash deposits as unexplained money under Section 69A of the Act, observed that, notices issued under Section 142(1) of the Act, were properly served and the father of the assessee had participated in the assessment proceedings as authorised representative by filing replies from time to time. The Ld. CIT(A) further observed that, although the assessee claimed that, the cash deposits were out of sale proceeds received from agricultural land, the assessee failed to furnish corroborative evidences to establish the source for cash deposit....

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.... available on record, has rightly treated the cash deposits as unexplained money under Section 69A of the Act, and the Ld. CIT(A), after appreciating the relevant facts, has rightly sustained the addition made by the A.O. Therefore, she submitted that, the order of the Ld. CIT(A) should be upheld. 8. I have heard both the parties and considered the relevant reasons given by the A.O. to make addition towards cash deposits into bank account during demonetization period for Rs. 11,97,504/- under Section 69A of the Income Tax Act, 1961. The A.O. made addition towards cash deposits on the ground that the assessee could not explain the source for cash deposit and the explanation offered by the assessee that the source for cash deposit was out ....