TaxTMI 
TaxTMI 
2025 (4) TMI 2097
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....income at Rs. 13,56,070/- as against returned income of Rs. 2,96,090/- 2. That the CIT(A) erred in confirming the action of the AO based upon surmises and conjecture without there being any evidence contrary to the contention of the assessee which is duly supported by documents. 3. That the CIT(A) has erred in confirming the addition of Rs. 10,59,980/- being cash deposited in bank account without appreciating that the said cash was part of the cash deposits made by the general public during demonetization, accepted by the assessee in the capacity of the Bank Business Correspondent/Facilitator, which were further duly transferred from the assessee's bank account to each depositors account by the Punjab National Bank. ....
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....ere made on behalf of clients and immediately transferred to their accounts, hence not his income. 7. Per contra, the Ld. DR relied on the order of the lower authorities. 8. We have heard the rival contentions and perused the material available on the record. 8.1. Ground Nos. 1 and 2 are general in nature, therefore, do not require adjudication. Accordingly, the same are dismissed. 9. Ground No. 3 is against the confirmation of addition of Rs. 10,59,980/- being cash deposited in bank account. 10. We have considered the findings recorded by the Ld. AO in the assessment order, as well as those of the Ld. CIT(A) in the appellate order. 10.1. During the course of the proceedings before us, the learned Counsel for the assessee ....
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....mission for the proceedings before the Ld. Commissioner (Appeals) are annexed herewith and market as Annexure-3. The Ld. CIT(A) passed the impugned order and upheld the ex-parte decision of the Ld. AO which is the subject matter of the instant Appeal. 10.2. We find that the assessee is engaged in the business of acting as a Bank Business Correspondent/Facilitator. In this line of business, the assessee collects money from small depositors and deposits it into a bank account, subsequently transferring the amount to the lead bank after deducting a certain percentage as commission, as permitted by the bank. As submitted by the learned Counsel for the assessee that this business model has been followed by the assessee for several years, and ....