TaxTMI 
TaxTMI 
2025 (3) TMI 1808
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....of the Income-tax Act, 1961 [hereinafter referred to as "the Act" for short], for Assessment Year (AY) 2017-18. 2. The grounds of appeal raised by the Assessee are as follows:- 1. On the facts and circumstances of the case and in law, the Order so passed by the Ld. CIT(A) NFAC is bad in law, illegal besides being in violation of the principle of natural justices & equity, as having been passed without considering the material already placed on records; as such liable to be quashed and set aside. 2. On the facts and circumstances of the case and in law, the Ld. CIT(A) NFAC has grossly erred in dismissing grounds of appeal so raised before him and thereby, further erred in concurring with the A.O. in making addition of Rs....
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....d investigation was made about the amounts credited in the bank account of the said firm. After examining bank accounts, it has been found that there have been deposits of funds in respect of Hariram Jagdish Prasad with Ratnakar Bank through cheque deposits and RTGS and cash deposits and immediately these funds were transferred to different banks from April 2016 to March 2017. Therefore, the Revenue alleged that this is the process of converting unaccounted cash of parties into cheque and earning commission thereon, paying taxes on commission. 4.2 An amount of Rs. 89,73,795/-, which was found to have been routed to M/s. LMK Texfab by M/s. Hariram Jagdish Prasad, was brought to tax being the unexplained income of the assessee u/ s. 69A of....
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.... On the merits of the case also, the Ld. Counsel for the assessee contended that 9. The Ld. DR, on the other hand, relied on the orders of the authorities below. 10. Heard both the parties and perused the material available on record. During the course of the assessment proceedings the JAO issued a notice u/s.142(1) of the Act, dated 13.11.2021 whereby, vide item no.5 of the annexure, asked the assessee to submit ledger folio for assessee's alleged transaction with M/s Hariram Jagdish Prasad (PAN: AACFN046N) and to explain the nature of the entries therein. In response to the same the assessee vide his letter dated 05.03.2022 categorically stated that the assessee does not have any transaction with M/s Hariram Jagdish Prasad (PAN: ....
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....fore to substantiate the claim that no such amount is transferred into the bank account of assessee, copy of bank statement of account no. 1111624840 with Kotak Mahindra Bank, Ahmedabad Branch for the period 01.04.2016 to 31.03.2023 was submitted before the authority along with a letter dated 25.09.2023 regarding closer of bank account no. 1111624840 w.e.f. 23.05.2016 along with copy of other bank account no. 4811768586 of Kotak Mahindra Bank in the name of Vivek M. Karnani & account no. 026919300006352 with HDFC Bank, R.S Puram Branch, Coimbatore in the name of Vivek M. Karnani and Bank account no. 8911328626 held with Kotak Mahindra Bank, Ahmedabad Branch in the name and style of Lakshmi Mills, another proprietary concern of the assessee.....