2026 (8) TMI 1657

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....the following grounds of appeal: "1. That under the facts and circumstances of the case, the order passed u/s 143(3) IT Act dt: 06.12.2019, which was upheld by the Ld. CIT(A), NFAC vide order passed u/s 250 of the IT. Act dt: 06.03.2026 is not in accordance with the facts of the case and the provisions of law. 2. That the Ld. CIT(A) has erred in upholding the assessment order without properly considering the factual matrix, documentary evidence, and submissions of the appellant. 3. The Ld. CIT(A) is not correct in upholding the action of the AO bringing to tax the cash deposits made in the bank account Rs. 14,09,000/-, as unexplained cash deposits invoking provisions of sec 69A of the IT Act. 4. The Ld. C....

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.... 4. Aggrieved by the Assessment Order, the assessee preferred an appeal before the Ld. CIT(A) and challenged the additions made by the Ld.AO towards Income from Other Sources and argued that the source of cash deposited into bank account is out of her known source of income from fishing farming. The assessee had also challenged additions made by the Ld.AO towards computation of long-term capital gains. Ld.CIT(A), after considering the submissions of the assessee and after taking note of relevant facts sustained the additions made by the Ld.AO, by holding that, the claim of savings from past declared income is unsubstantiated and further the appellant was failed to produce conclusive evidence to establish that she had no interest whatsoever....

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....he assessee has not challenged the additions made by the Ld.AO towards unexplained money under section 69A of the Act and long-term capital gains but only argued the higher rate of tax computed by the Ld.AO in terms of section 115BBE of the Act. 8. Learned Senior AR for the Revenue, Shri A.P.Babu, Sr.AR, relied upon the order of the Ld.CIT(A) and argued that the amendment to provisions of section 115BBE of the Act came into effect from 01.04.2017 and is applicable for the A.Y. 2017-18 and therefore the Ld.AO has rightly computed tax @60% on income assessed under the head "Income from other sources". Therefore, he submitted that the order of the Ld. CIT(A) should be sustained. 9. We have heard both the sides, perused the material avail....