TaxTMI 
TaxTMI 
2025 (12) TMI 1866
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....ing to different Assessment Years (AYs). Since common facts and issues are involved in all these appeals, these were heard together and are being disposed of by this consolidated order. Assessee's appeal in ITA No.1384/Ahd/2024 for AY 2014-15 is taken as a lead case for the purpose of narration of facts. ITA No.1384/Ahd/2024 for AY 2014-15 2. The assessee in this appeal is aggrieved by the action of the Ld. CIT(A) in confirming the addition of Rs.45,46,467/- made by the Assessing Officer (AO) on account of unexplained cash deposits by the assessee in Shri Renuka Mata Multi State Urban Co-operative Credit Society Ltd. 3. The brief facts of the case as extracted from the assessment order are that the assessee filed his return of inco....
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....that the re-opening of the assessment u/s.147 of the Act was bad in law as the AO had not supplied the reasons recorded for re-opening of the assessment. Further, it was pleaded that the assessee had categorically mentioned that the said account with Shri Renuka Mata Multi State Urban Co-operative Credit Society Ltd. was used by one Shri Natvarbhai Becharbhai Patel on assessee's name. He had done business of trading in agricultural submersible pumps which were sold to agricultrists and sale proceeds were deposited by him in the said account. It was also explained that Shri Natvarbhai B. Patel was friend of the father of the assessee and that he was in the business of share of submersible pumps in Maharashtra State. That the assessee was a y....
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....harashtra by different persons. He has further demonstrated that it is not a case, where there was any lump sum deposit of any amount. He, in this respect, explained that submersible pumps were soled/supplied by Shri Natvarbhai B. Patel to various agriculturists at various remote places in the State of Maharashtra, who in turn deposited the sale proceeds in account of the assessee in Shri Renuka Mata Multi State Urban Co operative Credit Society Ltd. He has further demonstrated that there were corresponding debit entries also. He, in this respect, had explained that the credit entries were against sales realization, whereas debit entries were regarding purchases of goods. He, therefore, has submitted that at the most even if the said deposi....
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....hat the reopening of the assessment in this case is bad in law as the only course available to the AO was to proceed u/s.153C of the Act and not u/s.147 of the Act. Further, he has submitted that mere deposit in the bank account itself did not give any presumption to the AO that the income of the assessee for the year under consideration had escaped assessment. He, in this respect, has submitted that the AO did not have any information that the assessee had deposited his unaccounted money in the said account and, therefore, there were no valid reasons to the AO to re-open the assessment. 8.1. In this case, the assessee has, from the accounts, shown that various small amount on different dates were performed deposits in the account of the....