2023 (4) TMI 1485

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.... Therefore, all these appeals are argued by the learned Authorized Representative on similar lines and the learned Departmental Representative also responded identically and therefore, these appeals are disposed off by the common order. 02. Brief facts of the case shows that assessee is an individual who has not filed her return of income for A.Y. 2008-09. 03. Search took place under Section 132 of the Income-tax Act, 1961 (the Act) on 6th March, 2018 in case of Satyam, Sangani, Shaligram group of companies. During search residential premises of Viral K Patel, Ahmadabad, was also covered as he is the key person handling the cash transaction relating to M/s Satyam Developers Limited. During the course of search certain incriminating do....

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....cember, 2021. Assessee was given many opportunities but did not elicit any response and therefore, finally show cause notice dated 16th December, 2021 was issued. 09. According to the show cause notice it was stated as per the seized Tally data of ledger account for the year ended on 31st March, 2008, that the assessee paid 1,11,00,000/- in cash to Shri Suresh Bhai for the purchase of the above property. 010. Assessee submitted that she is a senior citizen and the matter is too old but she denied that she paid any sum in cash. She also requested for further additional evidences. 011. The learned Assessing Officer made the addition of Rs.1,11,00,000/- as unexplained cash credit under Section 69 of the Income-tax Act, 1961 (the Act).....

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..... 016. The assessee filed appeal on 5th December, 2022, against assessment order through Dispute Resolution Panel Route for eight years on 5th December, 2022. 017. Meanwhile, the appellate order were passed by the learned CIT (A)-57, Mumbai for six years on 13th January, 2023 and therefore, on 10th March, 2023, assessee filed these six appeals before the ITAT arising out of CIT (A) route. 018. Thus, there are fourteen appeals filed by the assessee. 019. In the present case, search on 6th March, 2018, was carried out on Satyam group. Satisfaction note in case of the assessee was recorded on 31st March, 2021 for A.Y. 2008-09 to A.Y. 2011-12 and A.Y. 2012-13 to A.Y. 2017 18. According to first proviso to section 153C of the Income-....