TaxTMI 
TaxTMI 
2025 (3) TMI 1701
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....ot require any separate adjudication. Likewise, the issues raised in ground Nos. 12 & 13 in relation to levy of interest u/s 234B & 234C of the Act are consequential in nature and do not require any separate adjudication. Hence, the ground Nos. 1, 12 and 13 of the assessee's appeal are hereby dismissed as infructuous. 3. The issue raised by the assessee in ground Nos. 2 to 8 of its appeal are interconnected and pertains to the addition of Rs. 44,32,000/- by treating the cash deposit during the demonetization as unexplained money. 4. The relevant facts are that the assessee is an individual and engaged in the business of wholesale trading of saree through proprietary concern in the name and style of "Saraswati Saree Center". The assess....
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....2016 to 31.12.2016, the total cash sales amounted to Rs. 28,95,636/-, and out of this, a sum of Rs. 14,32,000/- was deposited in the bank account during said period in new denomination currency. 8. The assessee in support of her submission furnished cash deposit summary containing month wise detail of opening cash balance, cash from sales realization during the month, cash deposited during the month and closing balance for the moth. The said detail was provided from April 2016 to March 2017. 9. However, the learned CIT(A) found that the assessee during the assessment proceedings failed to furnish the details required by the AO. The details submitted during the appellate proceeding were in the nature of additional evidence which were s....
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.....1 The assessee during the assessment proceeding claimed that the cash deposit is out of business proceeds and in support of the claim furnished the extract of audited financial statements, statement of income, bank statement, debtors, creditors ledger. However, the AO made the addition in absence of other detail such cash sales, cash deposit and withdrawal made during the demonetization and prior to demonetization. 13.2 During the appellate proceeding the assessee has furnished additional document such as audited financial statement of previous financial year, month wise of summary of cash sales, cash deposit and closing balance, copy of vat return etc. However, the learned CIT(A) not considered the detail provided by the assessee by ho....
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....copy of abovementioned documentary evidence and pleaded to admit the same as additional evidence. At the outset, we find that these additional evidences are crucial evidence in order to decide the issue whether the loan taken by the assessee form Shri Suresh Patel was utilized for acquiring the land property or not and consequently the assessee should be allowed the claim of interest expenses as cost of improvement or not. Therefore, considering the importance of the additional evidence which has direct bearing on the outcome of the dispute, we hereby exercise the power conferred under rule 29 of Income-tax (Appellate Tribunal) Rule 1963 and admit the same. 13.6 In view of the above discussion and considering the nature of the evidence, ....
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.... the order of the learned CIT(A) the assessee is in appeal before us. 18. The learned AR before us reiterated that the interest income was already included in the profit loss account and thereby same was offered to tax. Therefore, making the addition of the same under the head income from other sources will amount to double addition. 19. On the other hand, the learned DR vehemently supported the order of the authorities below. 20. I have heard the rival contentions of both the parties and perused the materials available on record. Admittedly, the assessee has earned interest income on fixed deposits and from the party namely Shri Dalichand Amolakchand Kothari for an amount aggregating to Rs. 91,623/- only. The AO alleged that the i....