2026 (7) TMI 423

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....B of the Act on 26.05.2023. The sole grievance of the assessee is confirmation of protective addition of Rs. 236.80 Lacs. Having heard rival submissions and upon perusal of case records, our adjudication would be as under. 2. The assessee did not file return of income. Pursuant to investigation report of DDIT(Inv.), Ambala, it transpired that the assessee was maintaining a bank account no. 100010741884 with Indusind bank since 08.05.2012 jointly with his father Shri Surjit Singh and brother Shri Baljinder Singh. The cash of Rs. 236.80 Lacs was found deposited in the said bank account and to verify the same, the case was reopened. The amount of Rs. 236.80 Lacs was also added in the assessment of Shri Surjit Singh. The assessee stated that....

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...., he was fully responsible and deemed to be an equal owner of all transactions unless specifically rebutted by documentary evidences. A mere self-serving letter by father would not extinguish the legal ownership of assessee. The assessee was required to furnish cogent evidence linking the deposits with explained sources. However, he failed to produce registered sale deeds proving ownership of land by his mother / wife etc., evidence of receipt of sale consideration in cash, ITRs of mother and wife showing capital gains, Bank trail of cash movement from alleged land sale to impugned account. In the absence of such evidences, the assessee did not discharge his statutory onus. Therefore, the protective addition was justified and confirmed by L....