2026 (6) TMI 480

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....he assessee has raised the following grounds of appeal: "a. The Ld. CIT(A) has erred in passing the order u/s. 250 of the Act and is contrary to law, facts and circumstances of the case. b. The Ld. CIT(A) ought to have believed that the cash deposits made by the Appellant are out of the Voluntary donation received during the year; but failed to consider the same and has dismissed the appeal on ground that the donation receipts are self-made. c. The addition of Rs. 9,54,000/- has been made purely on surmises, conjectures, and suspicion without any cogent material or corroborative evidence, which is unsustainable in law. d. The CIT(A) grossly erred in sustaining the addition of Rs. 9,54,000/- as income, wit....

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....ation of the bank account and the entire transactions in the said bank account actually belonged to the assessee society. Accordingly, the case of the assessee society was reopened under section 147 of the Income Tax Act, 1961 ("the Act") and notice under section 148 of the Act was issued by the Ld. AO on 31.03.2021. The assessee submitted before the Ld. AO that due to technical problem, the assessee could not file return of income in response to the notice issued under section 148 of the Act. However, the assessee furnished copy of computation of income, receipts and payments account and balance sheet for Assessment Year 2017-18 before the Ld. AO. During the course of assessment proceedings, the Ld. AO observed that the assessee had deposi....

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.... bank accounts of the assessee society. The Ld. AR invited our attention to the receipts issued by the society to the donors placed at page nos. 117 to 280 of the paper book. The Ld. AR further invited our attention to the comparative month-wise chart of cash deposits made in the bank accounts for Financial Years 2015-16 to 2019-20 placed at page no. 88 of the paper book and demonstrated that the cash deposits made during the demonetization period in the year under consideration were not abnormal as compared to the cash deposits made during the corresponding periods in Financial Years 2017-18 to 2019-20. The Ld. AR also submitted that the relevant period falls during festival season and major donations are normally received by the society d....

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....laced at page no.88 of the paper book, which is to the following effect: Reddy Seva Sangham : Nandyal Summary of Cash Deposits from the F.Y 2015-16 to F.Y 2019-20 Month 1.4.2015 to 31.3.2016 1.4.2016 to 31.3.2017 1.4.2017 to 31.3.2018 1.4.2018 to 31.3.2019 1.4.2019 to 31.3.2020   Cash Deposit in Bank Cash Deposit in Bank Cash Deposit in Bank Cash Deposit in Bank Cash Deposit in Bank Apr - - - - - May - 70,000 - - - June - 26,500 - - - July 50,000 - - - - Aug 35,000 - 18,000 - - Sep 85,000 - 35,000 - - Oct - - 1,83,000 - - Nov - 7,75,000 10,63,973 7,34,842 ....